Document Type: EA-Administrative Record Index Field: Draft Environmental Assessment Proj ect Name: Horus Kentucky 1 Solar Project Proj ect Number: 2020-17
HORUS KENTUCKY 1 SOLAR PROJECT DRAFT ENVIRONMENTAL ASSESSMENT Simpson County, Kentucky and Sumner County, Tennessee
Prepared for: Tennessee Valley Authority Chattanooga, Tennessee
Submitted by: Horus Kentucky 1, LLC c/o Horus Renewables Corporation
Prepared by: Terracon Consultants, Inc.
June 2021
To request further information, contact: J. Taylor Cates NEPA Compliance Tennessee Valley Authority 1101 Market Street BR 2C-C Chattanooga, Tennessee 37402 E-mail: [email protected]
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Horus Kentucky 1 Solar Project Table of Contents
Table of Contents
CHAPTER 1 – PURPOSE AND NEED FOR ACTION ...... 6 1.1 Background ...... 6 1.2 Purpose and Need ...... Error! Bookmark not defined. 1.3 Scope of the Environmental Assessment...... Error! Bookmark not defined. 1.4 Public Agency and Involvement ...... Error! Bookmark not defined. 1.5 Other Environmental Reviews and Documentation...... Error! Bookmark not defined. 1.6 Permits, Licenses, and Approvals ...... Error! Bookmark not defined. CHAPTER 2 - ALTERNATIVES...... 11 2.1 Description of Alternatives...... 11 2.1.1 No Action Alternative ...... 19 2.1.2 The Proposed Action Alternative ...... 19 2.1.3 Alternatives Considered but Eliminated from Further Discussion ...... 19 2.2 Comparison of Alternatives ...... 20 2.3 Identification of Mitigation Measures ...... 22 2.4 The Preferred Alternative ...... 23 CHAPTER 3 – AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES ...... 24 3.1 Land Use, Natural Areas, Parks, and Recreation ...... 24 3.1.1 Land Use...... 40 3.1.2 Natural Areas, Parks, and Recreation ...... 40 3.2 Geology, Soils, and Prime Farmland...... 27 3.2.1 Geology ...... 40 3.2.2 Soils ...... 40 3.2.3 Prime Farmland ...... 40 3.3 Water Resources...... 40 3.3.1 Groundwater ...... 40 3.3.2 Surface Water and Wetlands ...... Error! Bookmark not defined. 3.3.3 Floodplains ...... 49 3.4 Biological Resources...... 50 3.4.1 Vegetation ...... 50 2.4.2 Wildlife ...... 51 2.4.3 Threatened & Endangered and Other Rare Species ...... 53 3.5 Cultural Resources ...... 60 3.6 Visual Resources...... 65 3.7 Noise ...... 69 3.8 Transportation...... 74 3.9 Air Quality and Climate Change ...... 75 3.10 Public Health and Safety...... 80 3.11 Solid Waste and Hazardous Waste ...... 81 3.12 Socioeconomics and Environmental Justice...... 83 3.12.1 Socioeconomics ...... 100 3.12.2 Environmental Justice...... 100 3.13 Cumulative Impacts ...... 100 3.14 Unavoidable Adverse Environmental Impacts...... 89 3.15 Relationship of Short-Term Uses and Long-Term Productivity ...... 89 3.16 Irreversible and Irretrievable Commitments of Resources...... 89
Draft Environmental Assessment i Horus Kentucky 1 Solar Project Table of Contents
CHAPTER 4 – ENV I RONMENTAL ASSESSMENT RECIPIENTS...... 91 4.1 Federal Agencies...... 91 4.2 Federally Recognized Tribes ...... 91 4.3 State Agenc ies ...... 91 4.4 Individuals and Organizations ...... 91 CHAPTER 5 – LIST OF PREPARERS...... 93 5.1 NEPA Project Management...... 93 5.2 Other Contributors ...... 93 CHAPTER 6 – LITERATURE CITED ...... 94
List of Appendices
Appendix A – Consultation Correspondence Appendix B – Geotechnical/Karst Report Appendix C – Natural Resources Reports Appendix D – Cultural Resources Reports Appendix E – Phase I Environmental Site Assessment Report
List of Tables
Table 2.1 Summary and Comparison of Alternatives by Resource Area...... 20 Table 3.1 Record of Managed and Natural Areas ...... 22 Table 3.2 Proposed Horus Kentucky Solar Project Soils Lista ...... 30 Table 3.3 Proposed Horus Kentucky Solar Project Prime Farmland Soils List ...... 50 Table 3.4 Farming Statistics for Simpson County and Kentuc ky ...... 53 Table 3.5 Streams Identified within Project Site ...... 50 Table 3.6 Streams Identified within Project Transmission Line Upgrades ...... 50 Table 3.7 Ponds Identified within Project Transmission Line Upgrades ...... 50 Table 3.8 Wetlands Identified within Project SIte ...... 50 Table 3.9 Wetlands Identified within Project Transmission Line Upgrades...... 50 Table 3.10 TVA Natural Heritage Database information for state and federally-listed species within a 10-mile search radius of the Project Site and within the counties in which the Project Site is located ...... 50 Table 3.11 TVA Natural Heritage Database information for state and federally-listed aquatic species within a 10-mile search radius and terrestrial species within the counties in which the Project Transmission Line Upgrades are located ...... 50 Table 3.12 List of Sound Pressure Levels of Common Indoor and Outdoor Noises ...... 82 Table 3.13 Common Construction Equipment ...... 83 Table 3.14 Common Farm Sound Levels...... 84 Table 3.15 AADT Counts from Two Traffic Stations...... 86 Table 3.16 National Ambient Air Quality Standards ...... 88 Table 3.17 Air Quality in Simpson County, Kentucky ...... 89
Draft Environmental Assessment ii Horus Kentucky 1 Solar Project Table of Contents
Table 3.18 Average Emissions of NAAQS Pollutants in Simpson County, Kentucky for 2017 ...... 90 Table 3.19 Per Capital Personal Income Data ...... 98 Table 3.20 Minority Population Data ...... 99
List of Figures
Figure 1.1 Proposed Project Site Layout ...... 6 Figure 2.1 Representative Photograph of Horus Kentucky Solar Project Area...... 7 Figure 2.2 Proposed Horus Kentucky Solar Project Site - Topographic Map ...... 8 Figure 2.3 Proposed Horus Kentucky Solar Project Site Layout ...... 19 Figure 2.4 Proposed Upgrades to Transmission Lines L5402& L5775 ...... 20 Figure 3.1 Proposed Horus Kentucky Solar Project Land Cover ...... 25 Figure 3.2 Proposed Horus Kentucky Solar Project Karst Feature Inventory Map 1 ...... 26 Figure 3.3 Proposed Horus Kentucky Solar Project Geophysical ERI & ATP Drilling Locations Map 1 ...... 29 Figure 3.4 Proposed Horus Kentucky Solar Project Kast Avoidance Area Map 1...... 29 Figure 3.5 Proposed Horus Kentucky Solar Project Karst Feature Inventory Map 2 ...... 33 Figure 3.6 Proposed Horus Kentucky Solar Project Geophysical ERI & ATP Drilling Locations Map 2 ...... 38 Figure 3.7 Representative Photograph of Sinkhole Feature Encountered During Karst Survey ...... 39 Figure 3.8 Representative Photograph of Open-Throat Sinkhole Feature Encountered During Karst Survey ...... 45 Figure 3.9 Representative Photograph of Open-Throat Sinkhole Feature Encountered During Karst Survey ...... 52 Figure 3.10 Proposed Horus Kentucky Solar Project Soils Map...... 73 Figure 3.11 Proposed Horus Kentucky Solar Project Site NWI Map ...... 76 Figure 3.12 Proposed Horus Kentucky Solar Project Site Wetland Delineation Map ...... 97 Figure 3.13 Proposed Horus Kentucky Solar Project Site FEMA FIRM Map ...... 98 Figure 3.14 Proposed Horus Kentucky Solar Project Site Habitat Types Map ...... 98 Figure 3.15 Representative Photograph of Forested Area within Proposed Horus Kentucky Solar Project Site ...... 98 Figure 3.16 Viewshed Analysis of Proposed Horus Kentucky Solar Project Site...... 98 Figure 3.17 Representative Photograph of the Visual Aesthetics of Horus Kentucky Solar Project Area ...... 98 Figure 3.18 Employment by Occupations in Simpson County...... 98 Figure 3.19 Employment by Indus tries in Simps on County ...... 98
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Symbols, Acronyms, and Abbreviations
AADT Average Annual Daily Traffic AC Alternating Current ACHP Advisory Council on Historic Preservation AJD Approved Jurisdictional Determination APE Area of Potential Effects BMP Best Management Practices CAA Clean Air Act CBMPP Construction Best Management Practices Plan CE Categorical Exclusion CEQ Council on Environmental Quality CFR Code of Federal Regulations CO Carbon Monoxide CO2 Carbon Dioxide CUP Conditional Use Permit CWA Clean Water Act dB Decibel dBA A-Weighted Decibels dbh Diameter at breast height DC Direct Current DEA Draft Environmental Assessment DNL Day-Night Average Sound Level EDR Environmental Data Resources EA Environmental Assessment EIS Environmental Impact Statement EO Executive Order EPA Environmental Protection Agency EPCRA Emergency Planning and Community Right to Know Act ESA Endangered Species Act FEMA Federal Emergency Management Agency FIRM Flood Insurance Rate Map FPPA Farmland Protection Policy Act GHG Greenhouse Gas GPR Ground Penetrating Radar GPS Global Positioning Systems HUC Hydrologic Unit Map IF Isolated Find IPaC Information for Planning and Consultation IRP Integrated Resource Plan IT Information Technology KPDES Kentucky Pollutant Discharge Elimination System KPSC Kentucky Public Service Commission KYSB Kentucky State Board on Electric Generation and Transmission Siting KYTC Kentucky Transportation Cabinet kV Kilovolt lf Linear feet MW Megawatt NAAQS National Ambient Air Quality Standards
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NEPA National Environmental Policy Act NESHAP National Emission Standards for Hazardous Air Pollutants NHPA National Historic Preservation Act NLEB Northern Long-Eared Bat NO x Nitrogen Oxide NPDES National Pollutant Discharge Elimination System NRCS Natural Resource Conservation Service NRHP National Register of Historic Places NPS National Park Service NWI National Wetlands Inventory O3 Ozone O&M Operation & Maintenance OHSA Occupational Safety and Health Act PAH Polynuclear Aromatic Hydrocarbon PM2.5 Particulate matter equal to or less than 2.5 micrometers in aerodynamic diameter PM10 Particulate matter equal to or less than 10 micrometers in aerodynamic diameter PV Photovoltaic PPA Power Purchase Agreement RCRA Resource Conservation and Recovery Act RFP Request for Proposal REC Recognized Environmental Condition SFHA Special Flood Hazard Areas SHPO State Historic Preservation Office SO2 Sulfur Dioxide SOI Secretary of the Interior SPCC Spill Prevention Control and Countermeasure SWPPP Storm Water Pollution Prevention Plan ROW Right-of-Way TDEC Tennessee Department of Environment and Conservation THC Tennessee Historical Commission TNW Traditional Navigable Waters TVA Tennessee Valley Authority TWRA Tennessee Wildlife Resource Agency USACE U.S. Army Corps of Engineers USDA U.S. Department of Agriculture USEPA United States Environmental Protection Agency USFWS U.S. Fish and Wildlife Service USGS U.S. Geologic Survey VOC Volatile Organic Compound WOTUS Waters of the U.S.
Draft Environmental Assessment v Horus Kentucky 1 Solar Project Chapter 1 – Purpose and Need for Action
CHAPTER 1 – PURPOSE AND NEED FOR ACTION 1.1 Introduction
The Tennessee Valley Authority (TVA) proposes to enter into a Power Purchase Agreement (PPA) with Horus Kentucky 1, LLC (referred to herein as Horus Kentucky Solar), the facility- specific entity affiliated with Horus Renewables Corporation (Horus Renewables), to purchase the proposed power generated by the Proposed Horus Kentucky Solar Project (Project). Under the terms of the conditional PPA between TVA and Horus Kentucky Solar, dated December 27, 2019, TVA would purchase the electric output generated by the proposed solar facility for an initial term of 15 years, subject to satisfactory completion of all applicable environmental reviews. The Project would include up to 69.3-megawatts (MW) alternating current (AC) in generating capacity and would be constructed and operated by Horus Renewables.
Following a detailed evaluation of various alternatives (please refer to Section 2), the Project would occupy approximately 550 acres of land, roughly five miles to the southeast of Franklin in Simpson County, Kentucky (see Figure 1.1 – Proposed Project Site Layout). The 550-acre tract is known herein as the “Project Site.” The Project would also include a transmission upgrade component (herein referred to as the Project Transmission Line Upgrades) that would occur along approximately 20.96 miles of existing TVA Transmission Lines L5402 and L5775 (see Figure 2.5 – Proposed Upgrades to Transmission Line L5402 & L5775). The Project Site would be occupied with multiple parallel rows of solar photovoltaic (PV) panels on single-axis tracking structures, associated racking, direct current (DC) to AC inverters, and project substation transformer which would connect to TVA’s existing L5402, 161-kilovolt (kV) transmission line, which would transmit power to the TVA network. TVA’s L5402 traverses the Project Site at its central-southeast corner.
Draft Environmental Assessment 6 Horus Kentucky 1 Solar Project Chapter 1 – Purpose and Need for Action
Figure 1.1 Proposed Project Site Layout
Draft Environmental Assessment 7 Horus Kentucky 1 Solar Project Chapter 1 – Purpose and Need for Action
1.2 Purpose and Need for Action
TVA is a corporate agency of the United States and the largest public power provider in the country. Through our partnership with 153 local power companies, TVA supplies energy across 80,000 square miles for 10 million people, 750,000 businesses, and 56 large industrial customers, including military installations and the U.S. Department of Energy facilities at Oak Ridge, Tennessee. Our service area includes parts of seven southeastern states called the Tennessee Valley. Since 1933, TVA’s mission has been to serve the people of the region to make life better. TVA continues to execute on that mission today as we serve the Tennessee Valley through our commitment to leadership and innovation in energy, the environment, and economic development. TVA has one of the largest, most diverse, and cleanest energy- generating systems in the nation characterized by low carbon, low rates, and high reliability – maintaining 99.999% reliability to customers since 2000.
TVA produces or obtains electricity from a diverse portfolio of energy sources, including solar, hydroelectric, wind, biomass, fossil fuel, and nuclear. The 2011 TVA Integrated Resource Plan (IRP) (TVA 2011) established the goal of increasing its renewable energy generating capacity by 1,500 to 2,500 MW by 2020. The IRP identified the various resources that TVA intends to use to meet the energy needs of the TVA region over the 20-year planning period while achieving TVA’s objectives to deliver reliable, low-cost, and cleaner energy and to reduce environmental impacts. TVA’s 2015 IRP (TVA 2015a) reinforced the continued expansion of renewable energy generating capacity, including the addition of between 175 and 800 MW (AC) of solar capacity by 2023. In June 2019, TVA released the final 2019 IRP and the associated EIS (TVA 2019a). This updated IRP provides further direction on how TVA will deliver clean, reliable and affordable energy in the Valley over the next 20 years, and the associated EIS describes the natural, cultural and socioeconomic impacts associated with the IRP. The 2019 IRP recommends solar expansion and anticipates growth in all scenarios analyzed, with most scenarios anticipating 5,000-8,000 MW and one anticipating up to 14,000 MW by 2038 (TVA 2019a).
In 2019, customer demand prompted TVA to release a Request for Proposal (RFP) for renewable energy resources (2019 Renewable RFP). The PPAs that resulted from this RFP (including the Horus Kentucky Solar PPA) will help TVA meet immediate needs for additional renewable generating capacity in response to customer demands and fulfill the renewable energy goals established in the 2019 IRP. Therefore, the Proposed Action would provide cost-effective renewable energy consistent with the IRP and TVA goals.
The Proposed Action would directly help TVA meet this need for additional solar capacity under its IRP. In addition, the construction and operation of the Project Site has the potential to minimize the cost of electricity within the area and reduce air emissions due to the lack of fossil fuels used to generate electricity.
1.3 Scope of the Environmental Assessment
Pursuant to the National Environmental Policy Act of 1969 (NEPA), and its implementing regulations promulgated by the Council of Environmental Quality (CEQ) under Title 40, Code of Federal Regulations (CFR), §§ 1500-1508, Regulations for Implementing the Procedural Provisions of the National Environmental Policy Act (CEQ Regulations), Federal agencies are required to evaluate the potential environmental impacts of their proposed actions. Therefore, this EA was prepared in accordance with NEPA and TVA’s Procedures for Implementing NEPA (18 CFR Part 1318; Updated March 27, 2020) to assess TVA’s
Draft Environmental Assessment 8 Horus Kentucky 1 Solar Project Chapter 1 – Purpose and Need for Action
Proposed Action and the associated impacts of the construction, operation, and interconnection.
This EA describes the existing environment within the Project Area, analyzes potential environmental impacts associated with the Proposed Action and the No Action Alternatives, and identifies and characterizes cumulative impacts that could result from the Proposed Action in relation to other on-going or reasonably foreseeable proposed activities within the surrounding area of the Project Site. As stated in the PPA, TVA’s obligation to purchase renewable power is contingent upon the satisfactory conclusion on the environmental review and TVA’s determination that the Proposed Action is deemed to be “environmentally acceptable and consistent with environmental analyses completed for and contained within TVA’s environmental review and prepared in accordance with Applicable Law”. To further determine the acceptability of the Proposed Action, TVA shall take into account Applicable Law, including laws protecting cultural, historic, archaeological, biological, and other environmental resources, and shall mean that the location, operation, and maintenance of the Project Site and any associated facilities shall not result in unacceptable impacts inconsistent with the purposes, provisions, and requirements of Applicable Law as well as other federal, state, and local environmental laws and regulations.
Based on TVA scoping, identification of applicable laws, regulations and policies, and executive orders, the EA identifies and analyzes the following resources areas: Land Use, Natural Areas, Parks, and Recreation; Geology, Soils, and Prime Farmland; Water Resources (Groundwater, Surface Water, Floodplains, Wetlands); Biological Resources (Vegetation, Wildlife, Threatened & Endangered and Other Rare Species); Cultural Resources; Visual Resources; Noise; Transportation; Air Quality and Climate Change; Public Health and Safety; Solid Waste and Hazardous Waste; Socioeconomics and Environmental Justice; and Cumulative Impacts.
Given the nature of the project, the following resources are not found in the study area or would not be impacted by any of the project alternatives: glint and glare analysis, and architectural survey along the Proposed Transmission Line Upgrades. It should be noted that no architectural survey was required along the Proposed Transmission Line Upgrades within Kentucky and Tennessee as any height change of the transmission lines are proposed to be no greater than 7-10 feet in height from the existing infrastructure.
The EA consists of the following six chapters discussing the alternatives considered, resource areas that would be potentially affected, and analysis of potential impacts. Additionally, the EA includes an Appendix, which contains applicable correspondence regarding the Project. The structure of the EA is outlined below:
o Chapter 1: Introduces the purpose and need for the Project, the decision to be implemented, related environmental reviews and consultation requirements, necessary permits or licenses, and the EA document overview. o Chapter 2: Describes the Proposed Action and No Active Alternatives, provides a comparison of the Alternatives considered, and discussed the Preferred Alternative. o Chapter 3: Discusses the affected environmental and potential impacts (direct and indirect) on the identified resource areas, as well as appropriate mitigation measures. In addition, it discusses cumulative impacts in relation to the other on-going and reasonably foreseeable proposed activities within the surrounding area of the Project site. o Chapter 4: Contains the list of recipients of the EA document.
Draft Environmental Assessment 9 Horus Kentucky 1 Solar Project Chapter 1 – Purpose and Need for Action
o Chapter 5: Contains the list of preparers of the EA document. o Chapter 6: Contains the list of references cited in preparation of this EA document. o Appendix: Consultation correspondence and comments received on Draft EA, Geotechnical Investigations and Karst Study Reports, Natural Resources Reports, Cultural Resources Reports, and Phase I Environmental Site Assessment Report.
1.4 Public Agency and Involvement
The Draft EA will be issued for public review and comment for a 30-day period from June 15 through July 15, 2021. The draft EA will be posted on the TVA website, and notices of its availability and requests for comments will be sent to government agencies, organizations, and individuals who have indicated an interest in the Project. TVA also typically announces its availability and requests for comments in a press release and in the local media outlets.
1.5 Other Environmental Reviews and Documentation
TVA conducted three separate Categorical Exclusions (CEs) on June 30, 2020, November 9, 2020, and December 16, 2020, to allow for geotechnical investigations to be conducted as part of the due diligence efforts to determine the feasibility of construction and potential need for acquisition of additional property in support of the Project. The geotechnical investigation scope of work included the use of diesel-powered all-terrain vehicle (ATV) or track-mounted drill rig for drilling to determine the general subsurface conditions and soil properties. The boreholes were subsequently backfilled with the soil cuttings to the existing ground surface. In addition, the remaining spoils were scatted on the surface around the bore location. The scope of work did not include any tree removal or construction of an access road to accommodate the drill rig.
1.6 Permits, Licenses, and Approvals
Based on the scope of the proposed construction activities, as described in Chapter 2, the Project would likely require a Kentucky Pollutant Discharge Elimination System (KPDES) construction general permit issued by the Kentucky Energy and Environment Cabinet. A general KPDES permit would require the development of a Stormwater Pollution Prevention Plan (SWPPP) and implementation of approved pollution prevention measures. The SWPPP would address the design, inspection, and maintenance of Best Management Practices (BMPs) utilized during construction activities. In addition, a Conditional Use Permit (CUP) issued by the Franklin-Simpson County Zoning Board of Kentucky would be required for the Project. Lastly, a Certificate to Construct a Merchant Electric Generating Facility issued by the Kentucky State Board on Electric Generation and Transmission Siting (KYSB), which is a division within the Kentucky Public Service Commission (KPSC) would be required for the site. Currently, a KYSB Case No. 2020-00417 has been assigned for the Project.
Draft Environmental Assessment 10 Horus Kentucky 1 Solar Project Chapter 2 – Alternatives
CHAPTER 2 - ALTERNATIVES Chapter 2 explains the rationale for identifying the alternatives to be evaluated, describes each alternative, provides a comparison of alternatives with respect to their potential environmental impacts, and identifies the preferred alternative.
This EA evaluates two alternatives: The No Action Alternative and the Proposed Action Alternative.
2.1 Description of Alternatives
2.1.1 The No Action Alternative This alternative provides a baseline of conditions against which the impacts of the Proposed Action Alternative can be measured. Under the No Action Alternative, TVA would not purchase the power generated by the Project under the 15-year PPA with Horus Renewables. Therefore, this Project would not be constructed, operated, or maintained by Horus Renewables. The existing conditions (such as land use, biological resources, visual resources, physical resources, cultural resources, and socioeconomics) within the Project Site would remain unchanged, the property would remain as agricultural land, and associated agricultural activities would likely continue on-site. Furthermore, TVA would continue to rely on other sources of power generation as described in its 2019 IRP, to ensure an adequate energy supply while still meetings its goals for increased renewable energy generating capacity. Environmental conditions in the Project Area would remain unchanged in the immediate future.
2.1.2 The Proposed Action Alternative Under the Proposed Action Alternative, TVA would purchase the power generated by the Proposed Horus Kentucky Solar Project under the 15-year PPA with Horus Renewables. This EA assesses the impact of TVA’s action to enter into the PPA and the associated impact of the construction and operation of the Project by Horus Renewables and the electrical interconnection.
Solar Facility Horus Renewables would construct, operate, and maintain an up to 69.3-MW PV solar power generation facility. The Project would be constructed on approximately 550 acres of privately- owned land which is comprised of four (4) currently farmed tracts of land located less than five miles southeast of Franklin, Simpson County, within the Commonwealth of Kentucky. Based on a review of information obtained from the Simpson County, Kentucky Property Valuation Administrator (PVA) record, the northwest portion of the Project Site is split into three (3) parcels: northeast parcel (Parcel ID No. 043-00-00-025.00; currently owned by Summers Rosdeutscher Farm LLC); northwest parcel (Parcel ID No. 043-00-00-026.00 currently owned by Summers Hodges Farm LLC); and southwest parcel (Parcel ID No. 044- 00-00-011.00; currently owned by Summers Hodges Farm LLC). The southeastern and southwestern portions of the Project Site are split by Tyree Chapel Road; however, both portions are included in one (1) parcel (Parcel ID No. 044-00-00-012.00; currently owned by Roger D. Hoffman). The Project Site is currently bound to the north by Interstate-65 (I-65) and Old County Farm Road; to the east by Tyree Chapel Road and Hendricks Road; to the south by Tyree Chapel Road; and to the west by railroad tracks (see Figure 1.1 – Proposed Project Site Layout). The Project Site would occupy predominantly cultivated agricultural fields (see Figure 2.1 – Representative Photograph of Horus Kentucky Solar Project Area).
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Figure 2.1 Representative Photograph of Horus Kentucky Solar Project Area
The Project Site is approximately 750 feet above sea level (ASL). The southeast portion of the Project Site is relatively flat, with a slight gradient towards the northeast. Southwest and northwest portions of the Project Site have varied topographic gradient due to rolling topography (see Figure 2.2 – Proposed Horus Kentucky Solar Project Site – Topographic Map).
Figure 2.2 Proposed Horus Kentucky Solar Project Site – Topographic Map
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The Project Site would be occupied with multiple parallel rows of solar PV panels on single- axis tracking structures, associated racking, 22 DC to AC inverters, and a project substation transformer. The Project would connect to the existing TVA transmission network by providing a new 161-kV tap point on the existing Franklin-Portland (L5402) 161-kV line that traverses the Project Site at its central-southeast corner, which would transmit power to the TVA network.
Approximately 500 acres of the 550 acres would be occupied by PV panels, and the remaining approximate 50 acres would be occupied by ancillary equipment and infrastructure to support the Project or would remain undeveloped. The PV panels would be mounted on motor-operated axis tracker structures, which are commonly referred to as single-axis trackers. These single-axis trackers are designed to pivot the panels along their north-south axes to follow the path of the sun across the sky from the east to west direction. The tracker assemblies would be constructed in parallel north-south rows using steel piles installed at an average of 7.5 feet off ground to the top of the panel at 55 degree full-tilt. The perimeter of the Project Site would be enclosed with security fencing (see Figure 2.3 – Proposed Horus Kentucky Solar Project Site Layout).
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Figure 2.3 Proposed Horus Kentucky Solar Project Site Layout
Draft Environmental Assessment 14 Horus Kentucky 1 Solar Project Chapter 2 – Alternatives
Network Transmission Line Upgrades In order to support the operations of Horus Kentucky Solar, structural upgrades to approximately 20.96 miles of existing transmission lines (L5402 and L5775) connecting to the Project would also be required. The Proposed Transmission Line Upgrades would encompass both structure replacements and upgrades along the edge of the existing right- of-way (ROW) and the height change of structures are proposed to be no greater than 7-10 feet in height from the existing infrastructure. All upgrade work would occur at existing TVA substations and on existing TVA transmission lines within existing ROW. No new property or easement rights would be needed. Transmission Line L5402 is approximately 10.94 miles in length that originates at the Project Site in Franklin, Kentucky, runs south and terminates in Portland, Tennessee. Transmission Line L5775 is approximately 10.03 miles in length that originates at Wilson, Tennessee, runs northeast and terminates in Gallatin, Tennessee. The proposed transmission line structure upgrades will herein be referred to as the “Project Transmission Line Upgrades” (see Figure 2.4 – Proposed Upgrades to Transmission Line L5402 & L5775). Therefore, the total area under evaluation in this Environmental Assessment (EA) is referred to as the “Project Area” which includes the 550-acre solar power generation facility and approximately 20.96 miles of proposed transmission line structure upgrades.
Draft Environmental Assessment 15 Horus Kentucky 1 Solar Project Chapter 2 – Alternatives
Figure 2.4 Proposed Upgrades to Transmission Lines L5402 & L5775
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Access Roads TVA’s Proposed Action would result in the need for additional access roads associated with the Project Transmission Line Upgrades. Access roads are typically about 12 to 16 feet wide and are surfaced with dirt, mulch, or gravel. Additional access roads would be needed to allow vehicular access to each structure and other points along the ROW. Typically, new permanent or temporary access roads used for transmission lines are located on the ROW whenever possible and are designed and located to avoid severe slope conditions and to minimize impacts to environmental resources. The details regarding the additional access roads are still being determined; therefore, additional supplemental environmental analysis would be completed for the proposed access roads at a later time, as appropriate and necessary based on the results of their proposed locations.
Construction Construction activities would take approximately 12 to 18 months to complete using a crew of approximately 100 workers. Work may occur up to seven days a week during daylight hours. Additional hours after dark could be necessary to make up schedule deficiencies or to complete critical construction activities. Night-time construction, if deemed necessary, would require lighting in some areas of the Project Site. Any additional night-time lighting would be downward-facing and timer and/or motion-activated to minimize impacts to wildlife and any surrounding sensitive receptors including nearby households. Construction of the Project Site would require site preparation to including surveying and staking, removal of vegetation, light grading and clearing, installation of a perimeter security fence, installation of sedimentation basins, and preparation of construction laydown areas. Following site preparation, solar arrays would be assembled and constructed which would include driving steel pikes for the tracker support structures, installation of the solar panels, and electrical connections and testing and verification of the facility’s functionality.
During construction, various acres within the Project Site would be used as construction assembly areas (also called laydown areas) for worker assembly, safety briefings, vehicle parking, temporary offices, and material storage. Some of the assembly areas, which would be spread out across many of the Project parcels, would be staged within the locations proposed for the PV solar arrays. The laydown areas would be on-site for the duration of construction. Temporary construction trailers for material storage and office space would be parked on-site. Following completion of construction activities, trailers, unused materials, and construction debris would be removed from the Project Site. Construction materials would be transported by track and/or rail to the Project Site, where materials would be staged, assembled, and moved into place. No operations and maintenance buildings or other permanent construction would be on-site.
Horus Kentucky Solar would use the existing landscape, such as slope, drainages, and roadways where feasible, minimizing grading work where practicable. Grading activities that could not be avoided would be performing using mobile earth-moving equipment, resulting in a fairly consistent slope on land. Native topsoil would be preserved to the greatest extent practicable during grading. In addition, native topsoil would be stockpiled on-site and preserved for redistribution over the disturbed area after grading is complete. After the construction, the disturbed areas would be seeded with native seed mixture of certified weed- free, low-growing, non-invasive grasses, and herbaceous plants. Flowering vegetation also would be used, if available, to attract pollinator species such as honeybees and butterflies. Furthermore, erosion control measures and BMPs would be inspected and maintained until the status of the vegetation within the disturbed areas returns to the pre-construction
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environment of the Project Site. Water would be used for fugitive dust control and/or soil compaction during construction on an as-needed basis.
To manage stormwater during construction, on-site temporary sediment traps and erosion control silt fence would be utilized. All buffered streams and wetlands would be protected by erosion control silt fences, and sediment traps would be placed in strategic drainage areas to prevent sediment from entering on-site stream and wetlands. Off-site sediment migration would be moderated by placement of silt fences around each area of ground disturbance within the Project Site. These stormwater BMPs would minimize the potential for sediment to enter on-site jurisdictional streams and wetlands and to minimize sediment migration off-site during construction. Once sufficient revegetation cover is achieved, the Project Site would be considered stabilized and temporary construction BMPs would be discontinued and/or removed.
Construction would be sequenced to minimize the time that bare soil on the disturbed areas would be exposed. As described above, silt fences would surround the perimeter of the area to be cleared and graded. Other appropriate controls such as temporary cover would be used as needed to minimize exposure to soil and to prevent eroded soil from leaving the work area. Disturbed areas including but not limited to road shoulder, construction office and laydown areas, ditches, and other Project-specific locations, would be seeded post-construction. If conditions require, soil may be further stabilized by mulch or sprayable fiber mat. As part of the KPDES permit authorization (see Section 1.7), the site-specific SWPPP would be finalized with the final grading and civil design and would address all construction-related activities prior to construction commencement.
The design of the tracker support structures could vary depending on the final PV technology and vendor selected. Based on preliminary geotechnical exploration results for the Project Site, the trackers would be attached to driven steel pile foundations. The steel pile foundations are typically galvanized and used where high load-bearing capacities are required. The pile would be driven with a hydraulic ram. Soil disturbance would be restricted to the pile insertion location to a depth typically less than 20 feet below grade. The solar panels would be manufactured off-site and shipped to the Project Site ready for installation. All final electrical collection cables would be underground, and electricians would run the electrical cabling throughout the Project Site. The trenches to hold the cabling are typically approximately 3 to 4 feet deep and 2 to 12 inches wide. The trenches would be backfilled with native soil and appropriately compacted.
Project Operations Operations of the Horus Kentucky Solar Facility would require routine maintenances such as periodic motor replacement, inverter air filter replacement, fence repair, vegetation control, array inspection, repairs, and maintenance. The Project would implement traditional mechanized landscaping using lawnmowers, string trimmers, etc. Traditional trimming and mowing would be performed periodically to maintain the vegetation at a height ranging from 6 inches to 2 feet. Selective use of herbicides may also be employed around structures to help control weeds. Products used would be limited to post-emergent herbicides and would be applied by a professional contractor. While some minor disturbance could occur to soils with traditional landscaping practices, no major physical disturbance would occur as a result of facility operation. Moving parts of the facility would be restricted to the east-to-west tracking motion of the solar modules, which typically amounts to a movement of less than 1-degree angle every few minutes which makes this movement barely perceptible. The solar modules would start to backtrack west to east in a similar slow motion to minimize shading in the late
Draft Environmental Assessment 18 Horus Kentucky 1 Solar Project Chapter 2 – Alternatives
afternoon. At sunset, the solar modules would track to a flat stow position. Otherwise, the solar modules would simply collect solar energy and transmit it to the TVA power grid.
With the exception of fence repair, vegetation control, and periodic array inspection, repairs, and maintenance, the Project Site would require relatively little human activity during operation. No water or sewer service, or permanent lighting would be requiremed on-site during project operations. In addition, precipitation in this region is adequate to remove dust and other debris from the PV panels while maintaining energy production. Therefore, manual panel washing is not anticipated unless a specific issue is identified. The Project Site would be monitored remotely to identify any security or operational issues. If a problem is discovered during non-working hours, repair or law enforcement personnel would be contacted if an immediate response is warranted.
Decommissioning and Reclamation Following the expiration of the 15-year PPA with TVA, Horus Renewables would reassess the Project operation and determine whether to cease operation or attempt to enter into a new PPA or other arrangement. If TVA or another entity is willing to enter into such an arrangement, the Project would continue operating. If no commercial arrangement is possible, the Project would be decommissioned and dismantled, and the Project Site would be restored. As the lease agreement with the landowners would be for an average of 30 to 40 years, site control would be maintained for longer than the 15-year PPA period, and Horus Renewables may attempt to renegotiate further PPA terms with TVA. In general, the majority of decommissioned equipment and materials would be recycled. Materials that cannot be recycled would be disposed of appropriately at approved facilities in accordance with applicable federal, state, and local laws and regulations. Horus Renewables would develop a decommissioning plan to document recycling and disposal of materials in accordance with applicable laws and regulations. If additional PPA terms are arranged or if TVA chooses to operate the facility, these activities would be evaluated through separate NEPA processes.
2.1.3 Alternatives Considered but Eliminated from Further Discussion In determining the suitability for development of a proposed solar facility within TVA’s existing service area that would meet the goals of expanding TVA’s renewable energy portfolio as determined in the 2019 IRP, various factors were considered to screen potential solar facility locations. Ultimately, various potential sites were eliminated as they did not provide the needed attributes such as location within TVA’s service area, location near existing electric infrastructure for interconnection, contiguous land to accommodate solar arrays, generally flat landscape with minimal slope, land with suitability geology for construction suitability, and minimal features like floodplains, wetlands, surface water features, or large forested areas. Lastly, through initial due diligence, Horus Renewables focused on land which would avoid or minimize impacts to known sensitive biological, visual, and cultural resources. While various tracts of land were considered as part of the initial due diligence, due to potential confidentiality issues, specific location and ownership details of previously considered tracts of land will not be provided in detail within this EA document. The process of screening potential locations and ultimately eliminating sites that did not possess the necessary attributes led to the selection of the Project Site.
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2.2 Comparison of Alternatives
The environmental impacts anticipated under the No Action and the Proposed Action Alternative are compared and summarized below in Table 2-1. These summaries are derived from the information and analyses provided in the Affected Environment and Environmental Consequences sections of each resource evaluated in Chapter 3.
Table 2.1 Summary and Comparison of Alternatives by Resource Area
Impa cts from No Resource Area Impa cts from Proposed Action Alternative Action Alternative Conversion of agricultural land to solar generation is consistent with Simpson County’s zoning. Minor direct adverse impacts as land use on the Project Site would change from agricultural to industrial. No direct or indirect Land Use, Natural Areas, Project construction would not result in a long- impacts anticipated Parks, and Recreation term adverse direct impact. The surrounding area is largely agricultural, undeveloped, and residential, which would not change. No indirect impacts to natural areas, parks, and recreation. Project would directly impact agricultural production for the duration of the Project. Minor direct impacts on potential shallow subsurface geological resources. In addition, minor temporary direct impacts related to erosion and Geology, Soils, and Prime No direct or indirect sedimentation during construction. Once Farmland impacts anticipated stabilized and Project is operational, impacts on soils would be offset by the beneficial effects to soil health with the use of native and non-invasive vegetation. Direct impacts on farmland from the conversion of agricultural land to solar generation for the duration of the Project. Potential minor beneficial impacts to groundwater and surface water from reducing fertilizer and pesticide runoff from current farming operations entering surface and/or groundwater once agricultural operations cease at Project Site. Minor temporary direct impacts from No direct or indirect sedimentation due to run-off from ground Water Resources impacts anticipated disturbing activities (minimized through implementation of BMPs) until Project Site is stabilized. Delineated streams and wetland features are being avoided as part of project design. No direct or indirect adverse impacts to wetlands. Minor direct impacts to floodplains due to access road construction. Three main vegetation communities would be affected: actively cultivated bean and corn fields, hay pastures, and forested land. Negligible and temporary minor impacts on wildlife during No direct or indirect construction. Wildlife that can use early Biological Resources impacts anticipated successional habitat is expected to return to Project Site once operational. No significant impact or long-term impacts on migratory birds of conservation concern. Seasonal species survey is
Draft Environmental Assessment 20 Horus Kentucky 1 Solar Project Chapter 2 – Alternatives
currently on-going for the Leafy Prairie Clover. If appropriate, TVA would consult with the U.S. Fish and Wildlife Services (USFWS) under Section 7 of the Endangered Species Act for federally listed species. As needed TVA also would confer with state agencies. Avoidance and minimization measures would be used to ensure no significant impacts to federal or state-listed species would occur. Due to TVA’s Avoidance Agreements for known NRHP-eligible and NHRP-listed sites, no impacts on archaeological resources would be anticipated. No direct or indirect Identified cultural resources would be avoided Cultural Resources impacts anticipated from ground disturbing activities in project design. Recommendation of no adverse effect on architectural resources. Minor temporary impacts would occur during construction due to the alteration of the existing agricultural viewshed and construction activity. Moderate direct impacts would occur during operation of Project Site due to presence and No direct or indirect quantity of solar panels. Impacts on residents Visual Resources impacts anticipated within the vicinity of Project Site would be minimized through the presence of existing natural screening buffers (forest areas and topography) as well as privacy fence and vegetative screening buffer that would be placed along Project boundaries. Minor temporary noise impacts during No direct or indirect Noise construction. Negligible adverse impacts from impacts anticipated noise associated with operation. Minor temporary impacts from increased traffic during construction (workers commuting to/from No direct or indirect Transportation Project Site and transportation of equipment). impacts anticipated Negligible direct impacts on transportation would occur from an operational standpoint. Minor temporary impacts in local air emissions from construction activities, but no impacts to air quality from an operational standpoint. Negligible increase in carbon dioxide from heavy equipment No direct or indirect Air Quality & Climate vehicles. However, net positive impact would impacts anticipated Change occur from operation of nearly emissions-free power generation by the Project, off-setting power that would otherwise be generated by the combustion of fossil fuels. Minor temporary impacts during construction. No No direct or indirect public health or safety hazards anticipated as a Public Health & Safety impacts anticipated result of Project operations. Minor impact from generation of solid waste Solid Waste & Hazardous No direct or indirect during construction. BMPs would be implemented W a ste impacts anticipated during construction.
Beneficial impacts to regional socioeconomics No direct or indirect Socioeconomics & from construction and operation of the Project, impacts anticipated Environmental Justice which would include the purchase of materials,
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equipment, and services and temporary increase in employment, income, and population. Loc al tax base would increase from construction of project with benefits to Simpson County region. Positive, long-term, direct impacts on economics and population from Project operation. No disproportionally high or adverse impacts to environmental justice (EJ) populations.
2.3 Identification of Mitigation Measures
Mitigation measures identified in Chapter 3 are summarized below. TVA’s analysis includes mitigation, as required, to reduce or avoid, minimize, or reduce adverse effects. Project- specific BMP’s are also identified.
o Implementation of the following TVA guidelines for the duration of the Project construction and operations: • A Guide for Environmental Protection and Best Management Practices for TVA Construction and Maintenances Activities. • TVA Environmental Quality Protection Specifications for Transmission Line Construction. • TVA Environmental Quality Protection Specifications for Transmission Substations or Communications Construction. • TVA ROW Clearing Specifications. • TVA Site Clearing and Grading Specifications. • TVA Substation Lighting Guidelines. • Unanticipated Discovery Plan. o Development and implementation of a SWPPP as prepared as part of the KPDES permitting process. o Development and implementation of a Spill Prevention, Control, and Countermeasures Plan (SPCC). o Installation of anti-reflective PV panel surfaces to minimize glare and reflection. o Maintain stormwater BMPs in each ground disturbing area until stabilization has been achieved. o Avoid direct impacts on streams and wetlands by maintaining a 50-foot buffer during construction. o Avoid direct impacts on identified caves and karst features by maintaining a 50-foot buffer during construction. o Plant or seed with non-invasive vegetation and include native and naturalized plant species to encourage beneficial habitat, reduce erosion, and limit the spread of invasive species. o Utilization of vegetation that benefits pollinator species to the extent practicable. o Utilization of timer and/or motion-activated downward facing security lighting to limit attracting wildlife, such as migratory birds or bats. o Utilization of dust mitigation activities such as watering dry exposed soils, covering open-body trucks, and establishing a speed limit to minimize fugitive dust. o Installation of temporary construction fencing around natural resources that should be avoided. o Installation of a privacy fence and vegetative screening buffer that would be placed along Project boundaries (where existing natural buffers are not sufficient in shielding adjacent residents).
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o Compliance with Simpson County set-back requirements: o 50 feet from any public road ROW. o 250 feet from any abutting residential zoned properties, rural village districts, churches, cemetery, school or nursing home. o 100 feet from any abutting internal or external agricultural zoned properties. o In addition, no structure may exceed the maximum height of 15 feet. However, under special circumstances in the development plan phase, the Planning Commission may approve a waiver for up to a maximum of 25 feet.
2.4 The Preferred Alternative
The Preferred Alternative that best fulfills the Purpose and Need is the Proposed Action Alternative. The Preferred Alternative would produce renewable energy for TVA and its customers with minimal direct and indirect environmental impacts, while at the same time having environmental benefits such as helping meet TVA’s current and future renewable energy goals.
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CHAPTER 3 – AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES Chapter 3 describes the existing environmental conditions of the Project Site and discusses the affected environmental and potential impacts (direct and indirect) on the identified resource areas if the No Action Alternative or the Proposed Action Alternative is implemented. In addition, it discusses cumulative impacts in relation to the other on-going and reasonably foreseeable proposed activities within the surrounding area of the Project Site.
3.1 Land Use, Natural Areas, Parks, and Recreation This section describes the existing land use, natural areas, parks, and recreation within the Project Area and the potential impacts on these resources that would be associated with the No Action and Proposed Action Alternatives.
3.1.1 Land Use
Affected Environment The U.S. Environmental Protection Agency (USEPA) defines “land use” as “the human use of land for activities such as agricultural, residential and recreational uses.” Imagery data collection from the National Land Cover Database identifies the entirety of the Project Site as “cropland”. The Project Site is relatively flat, with a slight gradient towards the northeast. Southwest and northwest portions of the Project Site have varied topographic gradient due to rolling topography. The closest town to the Project Site is the City of Franklin, which is located roughly five miles northwest of the Project Site. The Project Site does not include any residential structures. However, there are multiple residences that are directly adjacent to the Project Site boundaries. The areas immediately surrounding the Project Site are similar in land use and are primarily agricultural land and pasture land with scattered residential dwellings and limited commercial development.
Based on review of historical aerial photographs and topographic quadrangle maps, the Project Site appears to have been primarily utilized as agricultural land since at least 1950. The current land use of the Project Site has remained primarily agricultural with no significant land use changes in recent history. Horus Renewables would maximize the use of agricultural land to the greatest extent practicable, thus not requiring tree clearing and avoiding wetland impacts. Figure 3.1 below provides the land use classifications provided in the Natural Resource Conservation Service (NRCS) Land Use Land Cover Dataset.
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Figure 3.1 Proposed Horus Kentucky Solar Project Land Cover
The entire Project Site is located in a rural area of Simpson County and is zoned as “Agricultural”. The Franklin Simpson County Zoning Regulations stipulates zone districts which allow for siting of large-scale proposed solar power generation projects of 10 acres or greater through the issuance of a CUP. Simpson County also stipulates the following set- back requirements as part of their ordinances:
o 50 feet from any public road ROW. o 250 feet from any abutting residential zoned properties, rural village districts, churches, cemetery, school or nursing home. o 100 feet from any abutting internal or external agricultural zoned properties.
In addition, no structure may exceed the maximum height of 15 feet. However, under special circumstances in the development plan phase, the Planning Commission may approve a waiver for up to a maximum of 25 feet.
Environmental Consequences
No Action Alternative Under the No Action Alternative, the Project Site would not be constructed; therefore, no Project-related impacts to land use would result. Existing land use would be expected to remain agricultural for the foreseeable future. However, indirect impacts to land use are possible as growth occurs within the City of Franklin and Simpson County. Over time, it is possible that the agricultural areas within and surrounding the Project Site could be developed if the residential population in the area grows significantly. Additionally, if the
Draft Environmental Assessment 25 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences agricultural activities within the Project Site are discontinued, the existing land could revert to undeveloped property. Therefore, indirect impacts to land use are possible under the No Action Alternative as the current agricultural land may become residential, abandoned, or developed for other industrial purposes over the long-term.
Proposed Action Alternative Implementation of the Proposed Action would result in construction and operation of the Project Site; therefore, the land use within the Project Site would change from primarily agriculture to renewable energy production. The undeveloped forested portions of the Project Site would remain undeveloped. The Project Site is located within a rural area with limited zoning restrictions and would be compatible with land uses in the surrounding areas with the issuance of a CUP by Simpson County. If the Project Site were to be decommissioned, the land would be returned to agricultural production or used for a variety of other development strategies as allowed by the local zoning regulations. Minor direct impacts are anticipated from the conversion of actively cultivated agricultural land to solar generation. No impacts would be anticipated to land use within the Project Transmission Line Upgrades, as the land use within the existing corridor would not change.
3.1.2 Natural Areas, Parks, and Recreation
Affected Environment This section addresses natural areas (managed areas and sites) that are on, immediately adjacent to (within 0.5 miles), or within the region of the project area (5-mile radius). Natural areas include ecologically significant sites; federal, state, or local park lands; national or state forests; wilderness areas; scenic areas; wildlife management areas (WMAs); recreational areas; greenways; trails; Nationwide Rivers Inventory (NRI) streams; and Wild and Scenic rivers. Managed areas include lands held in public ownership that are managed by an entity (e.g., TVA, U.S. Department of Agriculture, U.S. Forest Service) to protect and maintain certain ecological and/or recreational features. Ecologically significant sites are either tracts of privately-owned land that are recognized by resource biologists as having significant environmental resources or identified tracts on TVA lands that are ecologically significant but not specifically managed by TVA’s Natural Areas program. NRI streams are free-flowing segments of rivers recognized by the National Park Service (NPS) as possessing remarkable natural or cultural values.
Based on a review of data from the TVA Natural Heritage Program, there are seven managed and natural areas within a 5-mile radius of the Project Site (see Table 3.1 – Record of Managed and Natural Areas):
Table 3.1 Record of Managed and Natural Areas
Managed Area Name GLB 91-19/White Oak Cave 25.97 acres Sumner County, TN Located greater than a mile south of the Project Site Porter Farm 89.65 acres Robertson County, TN Located greater than 2 miles southwest of the Project Site
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The Land Trust for Tennessee Easement 121.05 acres TN Located greater than a mile south of the Project Site Faith Grain Farm 102.2 acres Simpson County, Kentucky Located approximately one mile north of the Project Site Jamie Summers Farms 70.27 acres Simpson County, Kentucky Located approximately 1.5 miles north of the Project Site FMHA - Farmers Home Administration Easement 65.48 acres Robertson County, TN Located greater than 2 miles southwest of the Project Site FMHA – Robertson County Wetland – TWRA 68.95 acres Robertson County, TN Located greater than 2 miles southwest of the Project Site
It should be noted that the Project Site is not located within or immediately adjacent to a Federal, state, or local park, national or state forest, wildlife preserves, wilderness area, scenic areas, conservation easements, WMA, recreational areas, greenway, trails, NRI streams, or Wild and Scenic Rivers.
Environmental Consequences
No Action Alternative Under the No Action Alternative, the Project Site would not be constructed; therefore, no Project-related impacts to natural areas, parks, and recreation would result.
Proposed Action Alternative There are no outdoor recreational areas in the vicinity of the Project Site, and development of the Project would not impact public recreational activities or facilities associated with recreational activities. While there are seven managed and natural areas located within a 5- mile radius of the Project Site, direct impacts to these sites are not anticipated as activities would not occur within the boundaries or immediate vicinity of these natural areas. In addition, no impacts would be anticipated to natural areas, parks, and recreation within the Project Transmission Line Upgrades, as the activities would be temporary and would occur along the existing ROW.
3.2 Geology, Soils, and Prime Farmland This section describes the existing geological resources within the Project Area and the potential impacts on these geological resources that would be associated with the No Action and Proposed Action Alternatives. Components of geological resources that are analyzed include geology, geological hazards, soils, and prime farmland.
3.2.1 Geology
Affected Environment
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The Project Site is located within the Mississippian Plateau Physiographic Region of Kentucky, specifically within the Western Pennyroyal subsection. The Pennyroyal is largely farmland where underlain by limestone bedrock, particularly the St. Louis Limestone or Ste. Genevieve Limestone. In some areas of the Pennyroyal, the limestone is capped with an overlying sandstone stratum. Where the capping sandstone is intact, the land surface is usually forested, with rugged hills. In many places the sandstone has collapsed into the underlying karst-forming carbonate bedrock. The Pennyroyal region, consists of a limestone plain characterized by karst terrain, including sinkholes, sinking streams, stream-less valleys, springs, and caverns. Sinkholes or closed depressions on the ground surface are usually circular and often funnel-shaped and range in size from a few feet to hundreds of feet in diameter. There are relatively few surface streams in the region, and the sinkholes are often the principal surface drains. The karst terrain occurs in the eastern and southern parts of the region due to the presence of thick deposits of Mississippian-age limestones.
Referencing the USGS 7.5-minute topographic quadrangles for Frankfort, Kentucky- Tennessee, the parcels comprising the Project Site are in a broad, gently rolling lowland with numerous depressions. The ground surface within the Project Site ranges from about elevation 689 feet to 771 feet. The Project Site is mapped as underlain by bedrock of the Ste. Genevieve Limestone (Msg) and St. Louis Limestone (Msl) formations, both dated to the Upper Mississippian Sub-Period of the Carboniferous Geologic Period. These limestones are ranked by the Kentucky Geological Survey (KGS) as having a very high karst potential. The Ste. Genevieve is a thick-bedded oolitic limestone overlying the St Louis limestone formation characterized by scattered chert beds. The below rock unit descriptions are referenced from KGS:
o Ste. Genevieve Limestone (Msg): Predominantly oolitic; some crystalline, argillaceous, and fossiliferous, detrital interbeds. Light-gray to almost white, oolitic, medium crystalline, massive to thin-bedded or slightly cross bedded; contains thin shale partings. Gray to white, weathers slightly darker; where exposed to much direct sunlight, weathered rock may be white, commonly speckled red-brown by iron oxide stain; mostly thick bedded and massive but ranges to thin bedded. Upper limestone layers weather to a thick deep-red or maroon clay containing abundant residual chert. Much of residual chert weathers to chalky fragments. Ste. Genevieve grades imperceptibly into underlying St. Louis Limestone. o St. Louis Limestone (Msl): Limestone, light- to dark-gray, fine- to medium -crystalline; contains blue gray chert nodules, particularly abundant in uppermost part; several light- to medium-gray, oolitic limestone beds in upper part of unit; scattered colonies of corals in middle and lower part; scattered gypsum and anhydrite seams in lower part. Formation weathers to dark-reddish -brown chert residuum. Grades upward into Ste. Genevieve.
The L5402 corridor proposed for the Project Transmission Line Upgrade is situated within the Western Pennyroyal Karst Plain region of the Interior Plateau physiographic province. The L5775 corridor proposed for the Project Transmission Line Upgrade is within the Outer and Inner Nashville Basin regions of the Interior Plateau physiographic province. The Interior Plateau extends from southern Indiana and Ohio to northern Alabama. The open hills and irregular plains of the ecoregion are composed of Mississippian to Ordovician-age limestone, chert, sandstone, siltstone, and shale. The Western Pennyroyal Karst Plain is characterized by irregular plains with few perennial streams. Small sinkholes and depressions are common as the area consists of a thin loess mantle over Mississippian-age limestones. This region is noted for its fertile soils, and as such is used extensively for agriculture. Elevations typically
Draft Environmental Assessment 28 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences range from about 760 to 800 feet above mean sea level (AMSL) along the L5402 project corridor. The Outer Nashville Basin is characterized by rolling and hilly topography. The higher elevations are composed of Mississippian-age chert formations as well as Devonian- age Chattanooga shale. Streams are generally nutrient-rich. The Inner Nashville Basin is less hilly and lower in elevation than the Outer Nashville Basin; however, outcrops of the Ordovician-age limestone are common and were noted in the project area. The soils in this region tend to be more shallow and redder. Streams flow over large expanses of limestone bedrock, which was also noted often in the project area. Elevations typically range from about 445 to 650 feet AMSL along the L5775 project corridor.
Geological Hazards Geological hazards can include landslides, volcanoes, earthquake/seismic activity, and subsidence/sinkholes. The Project Site does not have conditions for a majority of these types of hazards with the exception of subsidence/sinkholes due to documented karst features. Sinkholes can be common when subsurface rock composition is evaporite rock (salt, gypsum, and anhydrite) and carbonates (limestone and dolomite) which can naturally be dissolved by groundwater circulating through them. When rock dissolves, spaces and caverns develop underground. These types of formations are referred to as karst topography. Land over sinkholes may stay intact until there is not enough support for the land above the formulated spaces. Eventually, a collapse of the land can occur, which can vary greatly in size and shape. Human activities can also expedite cavity formation in more susceptible materials and trigger a collapse or collapse an existing subsurface cavity site.
A preliminary geotechnical exploration (including Karst Survey) was performed in two separate phases within the Project Site. The field reconnaissance entailed walking the Project Site in a systematic manner to locate and delineate visible surface karst features (e.g., sinkholes and subsidence, closed depressions, and sinking and losing streams). Particular emphasis was on features inferred to have direct communication with the phreatic zone such as “open-throat” sinkholes, karst windows, cave entrances, and sinking streams. The geotechnical survey included subsurface exploration using Geophysical and air-track probe (ATP) drilling methods and Geophysical exploration using Electrical Resistivity Imaging (ERI) with an emphasis on karst features identified during the desktop review and field reconnaissance. Drilling exploration by ATP was performed at areas delineated with possible karst activity and along the ERI lines to calibrate the resistivity profiles, investigate anomalies revealed by the ERI, determine depth to bedrock, and explore for soil filled solution channels or voids. The following model layers within the subsurface profile were identified for the Project Site:
Model Layer Layer Name General Description 1 Cohesive Soil Lean Clay (CL) to Fat Clay (CH), brown to reddish brown, medium stiff to stiff 2 Cohesive Soil Lean Clay (CL) to Fat Clay (CH), with rock fragments, brown to reddish brown, very stiff to hard
Borings at 20 of 36 exploration locations were advanced to auger refusal at depths of about 12½ to 23 feet below existing grade. Auger refusal is defined as the depth below the ground surface at which a test boring can no longer be advanced with the soil drilling technique being used. Karst bedrock, such as the limestone formations underlying the Project Site are known for producing several obstructions that can cause the augers to refuse above sound bedrock.
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Due to the residual nature of the overburden soils, rock fragments, chert, and cobbles should be expected. Therefore, it is possible that piles driven into the overburden soils and weathered rock stratum might encounter difficult driving.
The geotechnical reports are provided in Appendix B. Figures 3.2-3.6 provides mapping of the karst features, geophysical ERI & ATP drilling locations, and karst avoidance areas for the Project Site.
Figure 3.2 Proposed Horus Kentucky Solar Project Karst Feature Inventory Map 1
Draft Environmental Assessment 30 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences
Figure 3.3 Proposed Horus Kentucky Solar Project Geophysical ERI & ATP Drilling Locations Map 1
Figure 3.4 Proposed Horus Kentucky Solar Project Kast Avoidance Area Map 1
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Figure 3.5 Proposed Horus Kentucky Solar Project Karst Feature Inventory Map 2
Figure 3.6 Proposed Horus Kentucky Solar Project Geophysical ERI & ATP Drilling Locations Map 2
Based on the results of the geotechnical survey, karst features are not expected to be reactivated by fill or structural loading. Reactivation of karst features will be sensitive to changes in surface water drainage and concentrated water flow. The Project Site has historically been used for agricultural purposes and has been stripped and grubbed over time.
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With no anticipated tree removal within the Project Site, interruptions to Project Site drainage and infiltration should be expected to be minimal. Figure 2.4 – Proposed Horus Kentucky Solar Project Site Layout includes the karst avoidance areas based on the results of the field survey and subsurface exploration. In general, the karst avoidance areas were set at 50-foot buffer from the mapped parapet of the closed depression. In cases where observations indicated sinkholes with open throats, apparent more recent subsidence shallow bedrock, and voids encountered by drilling, the buffer distance was increased to 100 feet. Figure 3.7- 3.9 are representative karst features encountered during the field reconnaissance within the Project Site.
Figure 3.7 Representative Photograph of Sinkhole Feature Encountered During Karst Survey
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Figure 3.8 Representative Photograph of Open-Throat Sinkhole Feature Encountered During Karst Survey
Figure 3.9 Representative Photograph of Open-Throat Sinkhole Feature Encountered During Karst Survey
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Environmental Consequences
No Action Alternative Under the No Action Alternative, the Project Site would not be constructed; therefore, no direct or indirect Project-related impacts on geology would result. Existing land use would be expected to remain agricultural land. However, the bedrock and overlying soil below the Project Site are susceptible to sinkhole development, and there can be extensive areas of shallow bedrock, and shallow groundwater, all of which can pose a risk to the future of the current land. Risk associated with these factors can be minimized with proper planning and design. Conversely, if agricultural practices were continued without proper caution, the risk of sinkhole and hydrologic-related damage to the Project Site would continue to exist.
Proposed Action Alternative Under the Proposed Action Alternative, minor direct impacts to geology would be anticipated as a result of construction and operation of the Project Site. Approximately 500 acres (of the total 550 acres) of the Project Site (which is 90 percent of the Project Site) would be cleared and/or lightly graded for the Project with the exception of culturally and biologically sensitive areas. The solar arrays would likely be supported by steel piles which would either be driven or screwed into the ground to a depth ranging of 6 to 10 feet. On-site sedimentation basins would be shallow and, to the extent feasible, utilize the existing terrain without requiring extensive excavation. The PV panels would be connected with underground wiring placed in excavated trenches and backfilled with Project Site native soil.
As indicated in the geotechnical report, the bedrock and overlying soil below the Project Site are susceptible to sinkhole development, there can be extensive areas of shallow bedrock, and shallow groundwater, all of which can pose a risk to the Project Site development process. Risk associated with these factors can be minimized during Project Site development with proper planning and design. Development plans should consider guidance for sinkhole surface drainage analysis in the KGS Ordinance for the Control of Urban Development in Sinkhole Areas in the Blue Grass Karst Region, Lexington, Kentucky as well as regulatory permits. Prior to the Project Site development, additional geotechnical studies would need to be conducted. Per Figure 2.4 – Proposed Horus Kentucky Solar Project Site Layout, the development of the Project Site incorporates the karst avoidance areas based on the results of the field survey and subsurface exploration. Therefore, identified karst features and caves would be avoided for the construction of the Project Site. Should hazards resulting from geological conditions occur, structural damage to PV panels, support structures, and other associated equipment could occur. Since the Project Site would not be staffed full-time during operation, potential damage to on-site structures would pose very limited risk to humans. Geologic hazard impacts on-site would be unlikely to impact off-site resources. Similarly, minor direct impacts would be anticipated to geology within the Project Transmission Line Upgrades, as the activities would be temporary and would occur along the existing ROW.
Should paleontological resources be exposed during construction or operation activities, a paleontological expert would be consulted to determine the nature of the paleontological resources, recover these resources, and analyze the potential for additional impacts, and develop and implement a recovery plan and mitigation strategy as appropriate.
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3.1.2 Soils
Affected Environment Based on the information from the USDA NRCS, the Project Site contains six known soil types. The predominant soil on the Project Site is Mountview silt loam, comprising approximately 58 percent of the on-site soil. The remaining soil types include Baxter gravelly silt loam, Nicholson silt loam, and Nolin silt loam. Figure 3.10 provides the approximate distribution area of each soil type while Table 3.2 provides a list of soils identified within the Project Site.
Figure 3.10 Proposed Horus Kentucky Solar Project Soils Map
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Table 3.2 Proposed Horus Kentucky Solar Project Soils List
Baxter gravelly silt loam is defined as deep, well drained, and is typically found on karst uplands, steep hillsides, and ridgetops. This soil color is typically yellowish brown to strong brown. Mountview silt loam soil is defined as deep, well drained and is typically found on sloping broad ridgetops and plateau-like areas. This soil color is typically brown to strong brown. Nicholson silt loam is defined as deep, moderately well drained, gently sloping, and is typically found on smooth ridgetops and stream terraces. This soil color ranges from brown to yellowish brown. Nolin silt loam is defined as moderately deep, sloping, well drained and is typically found on level floodplains and depressions receiving runoff. This soil color ranges from brown to dark yellowish brown.
Soils within the Project Transmission Line Upgrades are composed of silty, clayey, or loamy alluvium and residuum derived from sedimentary rocks such as limestone, siltstone, shale, and sandstone. Each of the soil types in the project area is below.
Section Soil Series Texture Slope Drainage Class L5204 Bewleyville Silty clay loam 2–12 % Well drained Di ckso n Silt loam2–5 % Moderately well drained Nolin Silt loamn/a Well drained; occasionally flooded Sengtown Gravelly silt loam 5–20 % Well drained L5775 Agee Silty clay loam n/a Poorly drained; rarely flooded Bradyville Silt loam2–12 % Well drained Byler Silt loam2–5 % Moderately well drained Capshaw Silt loam2–6 % Moderately well drained Eagleville Silty clay loam n/a Somewhat poorly drained; occasionally flooded Gladeville-Rock n/a 2–15 % Well drained; extremely stony Outcrop Complex Hampshire Silt loam5–20 % Well drained; eroded Inman Flaggy silt clay loam 5–30 % Well drained; eroded Lindell Silt loam0–2 % Moderately well drained; occasionally flooded Lomond Silt loam2–12 % Well drained; eroded Maury Silt loam2–5 % Well drained; eroded Nesbitt Silt loam2–5 % Moderately well drained Norene Silt loamn/a Poorly drained; rarely flooded Stiversville Silt loam5–12 % Well drained; eroded Talbott Silt loam2–20 % Well drained; eroded; rocky Tupelo Silt loam0–2 % Somewhat poorly drained Waynesboro Loam 12–20 % Well drained; eroded Udorthents n/a 2–8 % n/a
Draft Environmental Assessment 37 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences
Environmental Consequences
No Action Alternative Under the No Action Alternative, the Project Site would not be constructed; therefore, no direct or indirect Project-related impacts to soils would result. Existing land use would be expected to remain agricultural land. However, over time, impacts to soils could occur if the current land use practices are changed. Conversely, if agricultural practices were continued without proper conservation practices, soils could eventually become depleted in nutrients or erode, resulting in minor changes to the Project Site. The potential degradation of soil quality could be mitigated with proper farming practices such a terracing and application of soil amendments.
Proposed Action Alternative Under the Proposed Action Alternative, minor direct impacts to soil resources would be anticipated due to construction and operation of the Project Site. Much of the land in the Project Site would be cleared and/or graded for the Project with the exception of any biologically sensitive areas. The Project Site grading and clearing would cause minor impacts to soils, including minor localized increased in erosion and sedimentation. Minor disturbance to soils would occur during operations of the Project Site. Activities ranging from routine to non-routine maintenance of the solar arrays, array inspections, facility maintenance, fence repairs, and vegetation control would be an on-going potential disturbance to soils within the Project Site. Similarly, minor direct impacts would be anticipated to soil resources within the Project Transmission Line Upgrades, as the activities would be temporary and would occur along the existing ROW. Limited amount of ground disturbance would occur along discrete locations along the Project Transmission Line Upgrades, where new poles would be installed, or existing poles would be replaced. Excess soils from pole installation would be spread within the existing ROW or hauled to an approved disposal site. Areas within the existing ROW that are currently in cultivation would continue to be cultivated post-construction. Disturbed areas outside of actively cultivated areas would be re-seeded as necessary to prevent erosion within the ROW.
3.1.2 Prime Farmland
Affected Environment The 1981 Farmland Protection Policy Act requires all federal agencies to evaluate impacts to prime and unique farmland prior to permanently converting to land use incompatible with agriculture. The purpose of the Act is to “minimize the extent to which federal programs contribute to the unnecessary and irreversible conversion of farmland to non-agricultural uses.” Prime farmland is land that is the most suitable for economically producing sustained high yields of food, feed, fiber, forage, and oil seed crops. In addition, prime farmland has the best combination of soil type, growing season, and moisture supply available for agricultural use (i.e., not water or urban built-up land). The Project Site contains six soil types, three of which are considered prime farmland soils (Table 3.3 – Proposed Horus Kentucky Solar Project Prime Farmland Soils List).
Based on Information from the USDA NRCS, prime farmland soils occur on nearly 63 percent, encompassing over 348 acres of the Project Site. This is comprised of BaB, MoB, and NhB soils. The remaining soils, BaC, appears for Simpson County as farmland of statewide importance listing, but is not considered prime farmland, and No is considered prime farmland if protected from flooding or not frequently flooded during the growing season. The last soil
Draft Environmental Assessment 38 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences listing, BaD, is not considered prime farmland. Table 3.4 provides farmland statistics for Simpson County and Kentucky.
Table 3.3 Proposed Horus Kentucky Solar Project Prime Farmland Soils List
Soil Farmland Classification Hydric Area Percentage Type Rating (Acre s) of Area BaB All areas are prime farmland N/A 26.4 4.8 %
BaC Farmland of statewide importance N/A 170.4 30.9%
BaD Not prime farmland N/A 9.5 1.7%
MoB All areas are prime farmland N/A 316.8 57.5%
NhB All areas are prime farmland N/A 5.5 1.0% No Prime farmland if protected from flooding or not N/A 20.9 3.8% frequently flooded during the growing season Total Prime Farmland 348.7 63.3%
Table 3.4 Farming Statistics for Simpson County and Kentucky
Region Number of Farms Land in fa rms (Acre s) Simpson 471 110,864 County Kentucky 74,500 12,900,000
Environmental Consequences
No Action Alternative Under the No Action Alternative, the Project Site would not be constructed; therefore, no direct or indirect Project-related impacts on prime farmland would result. Existing land use would be expected to remain farmland. However, over time, impacts to prime farmland soils could occur if the current land use practices are changed. Conversely, if agricultural practices were continued without proper conservation practices, prime farmland soils could eventually become depleted in nutrients or erode, resulting in minor changes to the Project Site. The potential degradation of soil quality could be mitigated with proper farming practices such a terracing and application of soil amendments.
Proposed Action Alternative Under the Proposed Action Alternative, minor direct impacts to prime farmland soils would be anticipated as a result of construction and operation of the Project Site. Approximately 63 percent (348 acres) of land in the Project Site would be cleared and/or lightly graded for the Project Site with the exception of biologically sensitive areas, changing the land use from existing agricultural uses to renewable energy production. Implementation of the Proposed Action Alternative would result in temporary adverse effects to prime farmland during operation of the Project Site. Stockpiling topsoil for reuse and installing appropriate erosion control devices would further preserve topsoil at the Project Site. Adhering to BMPs during
Draft Environmental Assessment 39 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences construction and operation of the Project Site and revegetating the Project Site with native plant cover would limit erosion. Implementation of BMPs would result in minor impacts to prime farmland soils. Based on the above BMPs as well as availability of farmable land in Simpson County, impacts on prime farmland soils would be minor and mostly reversible.
Following the expiration of the PPA, the Project Site would be decommissioned as described in Section 2.1.2. Once Project equipment would be removed and the Project Site is stabilized, farming operations could subsequently be resumed with limited long-term loss of agricultural production and negligible loss to soil productivity.
Limited amount of ground disturbance would occur along discrete locations along the Project Transmission Line Upgrades, where new poles would be installed, or existing poles would be replaced. Upon completion, areas within the existing ROW that are actively cultivated would continue to be cultivated. Therefore, no loss of prime farmland or changes to agricultural practices are anticipated from the Project Transmission Line Upgrades.
3.3 Water Resources This section describes the existing water resources within the Project Area and the potential impacts on these water resources that would be associated with the No Action and Proposed Action Alternatives. Water resources discussed in this section include groundwater, surface water, wetlands, and floodplains.
3.3.1 Groundwater
Affected Environment Groundwater is water located beneath the ground surface, within soils and rock formation, Aquifers are rock units that have sufficient permeability to conduct groundwater and to allow economically significant quantities of water to be produced by man-made water wells and natural springs. Wells and natural springs provide approximately one-third of public domestic water supplies within the Commonwealth of Kentucky. Surface streams, the major source of Kentucky's water supply, are primarily sustained during base flow by groundwater discharge from adjacent aquifers. To be productive, the aquifer must be permeable and porous and retain qualities that allow water to flow through it easily. Sandstones, conglomerates, and fractured rocks can often be productive aquifers. The Project Site is located within the Mississippian Plateaus Region and lies within the West Fork of Drakes Creek portion of the Green River Drainage Basin in Simpson County, Kentucky.
The quality of groundwater in the Mississippian Plateaus Region varies considerably and is determined by the water's geologic source and the length of time it has been in contact with the rocks. Generally, deeper wells produce more mineralized water and are less likely to become polluted by anthropogenic activities. In Simpson County, water obtained from most drilled wells in limestone aquifers is considered hard. In addition, common salt and hydrogen sulfide are the two naturally occurring constituents most often encountered in objectionable amounts in groundwater.
As part of the geotechnical investigations, borings at 20 of 36 exploration locations were advanced to auger refusal at depths of about 12½ to 23 feet below existing grade at the Project Site. Auger refusal is defined as the depth below the ground surface at which a test boring can no longer be advanced with the soil drilling technique being used. Karst bedrock, such as the limestone formations underlying the Project Site are known for producing several obstructions that can cause the augers to refuse above sound bedrock. The boreholes were
Draft Environmental Assessment 40 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences observed while drilling and after completion for the presence and level of groundwater. Groundwater was not observed in any of the borings while drilling, or for the short duration the borings could remain open. However, this does not necessarily mean the borings terminated above groundwater. Due to the relatively low permeability of the soils encountered in the boring, a relatively long period of time may be necessary for a groundwater level to develop and stabilize in a borehole in these materials. Long-term observations in piezometers or observation wells sealed from the influence of surface water are often required to define groundwater levels in materials of this type. Groundwater level fluctuations occur due to seasonal variations in the amount of rainfall, runoff and other factors not evident at the time the borings were performed. Therefore, groundwater levels during construction of the Project Site may be higher or lower than the levels indicated on the boring logs. In particular, groundwater will tend to perch over the near- surface clayey and hardpan sands during and following periods of prolonged or intense rainfall. Based on the drilling, the Project Site’s groundwater is anticipated to consist of a horizontally and vertically discontinuous zone of overburden saturation perched atop underlying bedrock of relatively lower intrinsic primary permeability, likely within 20 feet below ground surface (bgs). Such overburden saturation zones, where present, are strongly controlled by bedrock surface topography and recent precipitation history. The possibility of groundwater level fluctuations should be considered when developing the design and construction plans for the Project Site.
According to the USEPA, there are no USEPA-designated sole-source aquifers located in Simpson County, Kentucky.
Environmental Consequences
No Action Alternative Under the No Action Alternative, the Project Site would not be constructed; therefore, no direct or indirect Project-related impacts on groundwater would result. Existing land use would remain as farmland, and groundwater resources would remain as they are at the present time. Increases in erosion and sediment runoff could occur over time if best practices in agriculture were not maintained to prevent erosion and runoff. In addition, if broad applications of chemical fertilizers or pesticides are continually used, it could result in nutrient- rich runoff that degrades the quality of groundwater within the Project Site and adjacent areas.
Proposed Action Alternative Under the Proposed Action Alternative, minor short-term impacts from construction would be expected on groundwater from sedimentation of exposed soils. BMPs would be installed, inspected, and maintained until satisfactory stabilization is achieved. In addition, hazardous materials would be on-site that could potentially contaminate groundwater resources. Hazardous materials that could be on-site include petroleum products for fuel and lubrication of construction equipment, hydraulic fluids, and a variety of other chemicals used for general construction projects. Implementation of BMPs would provide measures to minimize potential for leaks or spills from construction equipment as well as outline procedures and protocols to quickly address potential spills that may occur. Therefore, construction activities would be in accordance with BMPs outlined in TVA’s “A Guide to Environmental Protection and Best Management Practices for TVA Construction and Maintenance Activities” to avoid contamination to groundwater.
Water needed for construction of the Project Site would be provided from existing or proposed temporary groundwater wells or water delivery trucks. The construction contractor would use
Draft Environmental Assessment 41 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences water for the purposes of fugitive dust mitigation (during dry conditions), concrete mixtures, and other temporary construction needs. If practicable, groundwater wells and holding tanks would reduce and further avoid impacts to groundwater. Local rainfall is generally consistent enough to avoid the need for dust control on PV arrays. Therefore, regular panel washing is not anticipated during operations of the Project Site. Groundwater withdrawal volumes during construction and operations of the Project Site are expected to be significantly less than the existing volume needed for agricultural irrigation, thus resulting in a net positive impact on groundwater resources. Overall impacts to local aquifers and groundwater are not anticipated due to the limited volume of groundwater required for construction, operation, maintenances, and eventual decommissioning of the Project Site.
Per Section 3.1.1, multiple sinkholes were identified within the Project Site. Figure 2.4 – Proposed Horus Kentucky Solar Project Site Layout includes the karst avoidance areas based on the results of the field survey and subsurface exploration, which would eliminate the potential for direct groundwater contamination from stormwater, chemical, or solid waste runoff during construction and operations of the Project Site.
Beneficial, direct impacts to groundwater would result from a reduction in broad applications of pesticides, herbicides, and fertilizers used in support of the current agricultural operations. Additionally, water quality may be improved through filtering by native plant cover as opposed to crop cover, which could reduce erosion and sedimentation from stormwater events. Minor application of fertilizer may be needed for initial revegetation following construction of the Project Site. Therefore, this application would be in accordance with the manufacturer’s recommendation and be short-term. Change in land use from agriculture to solar power generation would be a long-term beneficial impact to groundwater.
No direct impacts are anticipated to groundwater within the Project Transmission Line Upgrades, as the activities would be temporary and would occur along the existing ROW.
3.4.2 Surface Water and Wetlands
Affected Environment Territorial seas and traditional navigable waters (TNWs), includes large rivers and lakes, such as the Ohio River. Surface waters are defined as water features that are on the surface, typically consisting of streams, lakes, ponds, and wetlands. Surface water features are further segregated into perennial, intermittent, and ephemeral. Perennial waters are permanent surface water features that have water present throughout the year. They typically exist as streams, rivers, lakes, springs, and swamps. During periods of limited or no precipitation, the water level is maintained by groundwater contributions. Intermittent classification is generally restricted to streams that have a well-defined channel, but only contain water part of the year, typically during winter and spring seasons when the stream bed is below the water table. Intermittent streams often do not support the diversity of biological and hydrological characteristics that perennial streams do. Ephemeral waters are features that only hold water for part of the year or flow as a result of stormwater events. Ephemeral streams, also known has wet-weather conveyances, are features that only flow in direct response to precipitation events. Flow would only occur during and shortly after large precipitation events. These features typically lack the biological, hydrological, and physical characteristics of intermittent and perennial streams. Examples of ephemeral streams and drainages include topographic swales or dry-drainages with poor bed and bank development. Wetlands are areas inundated by surface or groundwater often enough to support vegetation or aquatic life that requires saturated or seasonally saturated soil conditions for growth and
Draft Environmental Assessment 42 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences reproduction. Wetlands generally include swamps, marshes, bogs, and similar areas such as sloughs, potholes, wet meadows, mud flats, and natural ponds. Wetlands generally have three essential characteristics: hydrophytic (wetland) vegetation, hydric soils, and wetland hydrology.
Surface waters that meet certain physical and hydrologic criteria (defined bed and bank, ordinary high-water mark, or specific hydrologic, soil, and vegetation composition) as defined in the Clean Water Act (CWA) are considered Waters of the United States (WOTUS) and are under the regulatory jurisdiction of U.S. Army Corps of Engineers (USACE). The CWA is the primary federal law that regulates discharges of pollutants and/or fill materials into WOTUS as outlined in Sections 402, 404, and 401. A jurisdictional determination by the USACE typically governs the activities affecting WOTUS. Additionally, EO 11990 instructs federal agencies to “avoid to the extent possible the long and short-term adverse impacts associated with the destruction or modification of wetlands and to avoid direct or indirect support of new construction in wetlands wherever there is a practicable alternative.”
The eastern and southern portions of the Project Site appear to drain to the east-northeast into a tributary of West Fork Drakes Creek, located approximately 1,000 feet east of the Project Site. The western and northern portions of the Project Site do not have apparent drainage pathways. Based on the review of the LIDAR generated 2-foot contour map, it appears that the Project Site generally drains surface water externally off the site toward north and northeast side of the parcels with some closed depression locations within the parcels that drain surface water internally. The USGS map indicates the presence of multiple intermittent and perennial streams, as well as ponds across the Project Transmission Line Upgrades. Named streams include Cooks Branch, Spencer’s Creek, and the Cumberland River in the southern portion, and Grace Creek, and West Fork Drakes Creek in the northern portion.
A wetland delineation was conducted and is included in Appendix C which was performed to determine if wetlands or other waters under the jurisdiction of the USACE and the Kentucky Division of Water (KDOW) are present within the Project Area. Prior to conducting the field survey, aerial photographs, USGS topographic maps, National Wetlands Inventory (NWI) maps, and soil survey maps were reviewed to identify current and historic drainage patterns of the Project Area and connectivity of potential wetlands to other jurisdictional wetlands. The field investigation was conducted to evaluate areas of potential jurisdiction using procedures established for delineations as found in the USACE 1987 Wetland Delineation Manual and with additional information as provided in the Eastern Mountains and Piedmont Regional Supplement.
The NWI Map of the Project Site is published by the USFWS and depicts probable wetland areas based on stereoscopic analysis of high-altitude aerial photographs and analysis of infrared bands from remotely-sensed imagery. The NWI map for the Project Site depicts eight freshwater, excavated ponds (PUBHx, PUBSCx, and PUBFx) in the western and northern portions of the Project Site and two freshwater, excavated ponds (PUBHx and PUSCx) in the southern and eastern portions of the Project Site. The NWI map depicts three perennial streams (R5UBH and R2UBH), four ponds (PUBHh and PUBHx), three intermittent streams (R4SBA and R4SBC), one forested wetland (PFO1A) and two emergent wetlands (PEM1C) throughout the northern portion and depicts one lake (L1UBH), seven ponds (PUBHx, PAB, and PUBSx), one forested wetland (PFO1A), and eight intermittent streams (R4SBC) throughout the southern portion of the Project Transmission Line Upgrades. Figure 3.11 summarizes the wetland type data from NWI for the Project Site.
Draft Environmental Assessment 43 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences
Figure 3.11 Proposed Horus Kentucky Solar Project Site NWI Map
Figure 3.5-3.6 summarizes the streams that were identified within the Project Area:
Table 3.5 Streams Identified within Project Site Streams Length Flow Regime Average Stream USACE TVARAM (linear feet) Width at Top of Jurisdictional SCORES Bank (feet) (Y/N) 1 451 Ephemeral 7-9 No N/A 2 442 Ephemeral 7-9 No N/A 3 462 Ephemeral 5-7 No N/A TOTAL 1,355 lf
Draft Environmental Assessment 44 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences
Figure 3.12 Proposed Horus Kentucky Solar Project Site Wetland Delineation Map
Table 3.6 Streams Identified within Project Transmission Line Upgrades Streams Length Flow Average Stream USACE TVARAM (linear Regime Width at Top of Jurisdictional SCORES feet) Bank (feet) (Y/N) 1 (West Fork Dry 487 Perennial 7-9 Y 68 Creek) 2 101 Intermittent 7-9 Y 34 3 106 Ephemeral 5-7 N N/A 4 659 Ephemeral 2-4 N N/A 5 106 Ephemeral 5-7 N N/A 6 172 Intermittent 2-4 Y 34 7 83 Ephemeral 2-4 N N/A 8 (Grace Creek) 138 Perennial 1-3 Y 40 9 154 Ephemeral 2-4 N N/A 10 (Cumberland River) 122 Perennial 2-4 Y 68 11 112 Intermittent 2-4 Y 25 12 296 Ephemeral 5-7 N N/A 13 106 Ephemeral 5-7 N N/A 14 33 Ephemeral 5-7 N N/A 15 37 Ephemeral 3-5 N N/A 16 116 Intermittent 2-4 Y 20 17 54 Intermittent 10-12 Y 34 18 114 Ephemeral 3-5 N N/A 19 102 Perennial 3-5 Y 37 20 205 Intermittent 3-5 Y 35 21 (Dry Fork Creek) 113 Perennial 3-5 Y 41 22 116 Intermittent 5-7 Y 24
Draft Environmental Assessment 45 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences
23 105 Intermittent 3-5 Y 34 24 105 Intermittent 3-5 Y 34 25 361 Ephemeral 3-5 N N/A 26 (Spencer Creek) 133 Perennial 2-4 Y 47 27 (Cooks Branch) 136 Perennial 8-10 Y 44 28 200 Intermittent 2-4 Y 23 29 109 Ephemeral 5-7 N N/A 30A 133 Ephemeral 2-4 N N/A 30B 373 Intermittent 5-7 N N/A 31 126 Ephemeral 5-7 N N/A 32 105 Ephemeral 5-7 N N/A 33 117 Intermittent 5-7 Y 27 TOTAL 5,535 lf
Streams 3-5, 7, 9, 12-15, 18, 25, 29, 30, 31, and 32 are considered ephemeral, which would likely be considered non-jurisdictional features by the USACE per 33 CFR 328.3(b)(3). The remainder of on-site streams are considered intermittent or perennial, which are considered jurisdictional waters of the U.S.
Other waters were not identified within the Project Site. The following ponds were identified within the Project Transmission Line Upgrades:
Table 3.7 Ponds Identified within Project Transmission Line Upgrades Pond Size (acres) Cowardin Water Sources USACE Classification Jurisdictional (Y/N) A 0.70 PUBHx Precipitation, Surface Runoff, N B 0.10 PUBHx Precipitation, Surface Runoff N C 0.12 PUBHx Precipitation, Surface Runoff N D 0.25 PUBHh Precipitation, Surface Runoff N E 0.02 PUBHx Precipitation, Surface Runoff N F 0.01 PUBHx Precipitation, Surface Runoff N G 0.03 PUBHx Precipitation, Surface Runoff N H 0.22 PUBHx Precipitation, Surface Runoff N I 0.02 PUBHx Precipitation, Surface Runoff N J 0.06 PUBHx Precipitation, Surface Runoff N K 0.01 PUBHx Precipitation, Surface Runoff N L 0.01 PUBHx Precipitation, Surface Runoff N TOTAL 1.55 acres
PUBHh/ PUB Hx – Palustrine unconsolidated bottom; diked or impounded
The above-identified ponds do not appear to have connections to Traditional Navigable Waters (TNWs) and would likely be non-jurisdictional waters of the U.S., per 33 CFR 328.3(b)(8).
Figure 3.8-3.9 summarizes the wetlands that were identified within the Project Area:
Draft Environmental Assessment 46 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences
Table 3.8 Wetlands Identified within Project Site Wetland Size Cowardin Water Sources USACE TVARAM (acres) Classification Jurisdictional Scores (Y/N) Precipitation, Surface A 0.22 PEM N N/A Runoff TOTAL 0.22 PEM – Palustrine emergent w etland
Table 3.9 Wetlands Identified within Project Transmission Line Upgrades Wetland Size Cowardin Water Sources USACE TVARAM (acres) Classification Jurisdictional Scores (Y/N) Precipitation, Surface 32 1.49 PEM Y A Runoff Precipitation, Surface 15 0.01 PEM N B Runoff Precipitation, Surface 19 0.06 PEM N C Runoff Precipitation, Surface 38 D 0.10 PEM Y Runoff Precipitation, Surface 26 0.01 PEM Y E Runoff Precipitation, Surface 64 2.63 PEM N F Runoff Precipitation, Surface 35 0.98 PEM Y G Runoff Precipitation, Surface 19 H 0.08 PEM N Runoff TOTAL 5.36 PEM – Palustrine Emergent Wetland; PSS – Palustrine Scrub-Shrub Wetland; PFO – Palustrine Forested Wetland
Within the Project Site, one wetland, totaling 0.22-acres was identified on-site. The wetland is considered to be non-jurisdictional based on the lack of significant nexus to TNWs. This decision is based on 33 CFR 328.3(b)(1), which includes waters or water features that are not identified in 33 CFR 328.3(a)(1), (2), (3), or (4). In addition, three streams, totaling 1,355 linear feet, were identified within the Project Site. These streams are considered non- jurisdictional based on their ephemeral flow status and lack of connection, due to termination in karst features, to TNWs. This decision is based on 33 CFR 328.3(b)(3), which defines ephemeral features as including ephemeral streams, swales, gullies, rills, and pools.
Within the Project Transmission Line Upgrades, eight wetlands, totaling 5.36-acres were identified on-site. Wetlands B, C, F, and H do not appear have significant connection to any on-or-off site TNWs and are therefore considered non-jurisdictional by the USACE. This decision is based on 33 CFR 328.3(b)(1), which includes waters or water features that are not identified in 33 CFR 328.3(a)(1), (2), (3), or (4). The remaining on-site wetlands appear to have a connection to TNWs and are considered jurisdictional by the USACE. In addition, 33 streams, totaling 5,535 linear feet, were identified on-site during the site reconnaissance. Streams 3-5, 7, 9, 12-15, 18, 25, 29, 30, 31, and 32 are considered ephemeral, which are considered non-jurisdictional features by the USACE. This designation is based on 33 CFR
Draft Environmental Assessment 47 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences
328.3(b)(3), which identifies ephemeral features as ephemeral streams, swales, gullies, rills, and pools. The remainder of on-site streams are considered intermittent or perennial, which are considered jurisdictional by the USACE. Lastly, 12 ponds, totaling 1.55-acres, were identified on-site during the site reconnaissance. The on-site ponds do not appear to have connections to TNWs and are therefore considered non-jurisdictional by the USACE. This designation is based on 33 CFR 328.3(b)(3), which identifies ephemeral features as ephemeral streams, swales, gullies, rills, and pools.
Environmental Consequences
No Action Alternative Under the No Action Alternative, the Project Site would not be constructed; therefore, no Project-related impacts to surface waters and wetlands would be expected to occur. Existing land use would remain agricultural and the water resources would remain as they are at the present time. However, indirect impacts to surface water and wetlands could result from the continuing use of the Project Site as agricultural land. Increases in erosion and sediment runoff could occur if farming practices are not maintained using appropriate BMPs. Erosion and sedimentation at the Project Site could alter runoff patterns and impact downstream surface water quality. In addition, the continued use of chemical fertilizers, pesticides, and herbicides could impact water resources if the local aquifers are recharged from surface water runoff.
Proposed Action Alternative Under the Proposed Action Alternative, minor temporary direct impacts from sedimentation due to run-off from ground disturbing activities would be anticipated until the Project Site is stabilized. Soil erosion and sedimentation can clog small streams and threaten aquatic life. Appropriate BMPs would be followed, and Project construction activities would be conducted in a manner to ensure waste materials are contained and the introduction of pollution materials to the receiving waters would be minimized. A general construction stormwater permit would be needed as more than one acre of land would be disturbed. The permit would also require the development and implementation of a SWPPP. During construction of the Project Site, portable toilets would be provided for the construction workforce as needed. The portable toilets would be pumped out regularly, and the sewage would be transported by tanker truck to a publicly-owned wastewater treatment facility.
Due to location and easement constraints, complete avoidance of impacts to jurisdictional water features and wetlands along the Project Transmission Line Upgrades may not be practicable. Per the wetland delineation conducted, eight wetlands, 34 streams, and 12 ponds were identified along the 100-foot wide survey corridor within the Project Transmission Line Upgrades. During stages of the design process, efforts would be made to avoid and minimize impacts to jurisdictional waterbodies and wetlands to the greatest extent practicable. TVA is subject to EO 11990, Protection of Wetlands. Under the Proposed Action, impacts to jurisdictional waterbodies and wetlands are anticipated to be minor and temporary.
As the current Project Site layout shows, the area of impact has been designed to avoid impacts to delineated streams and wetland features with appropriate buffers. In addition, adherence to TVA specifications and BMPs would ensure that the upgrade/improvement activities do not adversely affect delineated wetlands. Construction and operation of the Project Site would not affect jurisdictional streams or wetlands.
Draft Environmental Assessment 48 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences
As described above for groundwater, minor beneficial, direct impacts to surface water would result from the change in land use and reduction in the amount of fertilizer and pesticide runoff to surface water resources.
3.4.3 Floodplains
Affected Environment A floodplain is the relatively level land area along a stream or river that is subject to periodic flooding. Flood hazard areas are identified on the Flood Insurance Rate Map (FIRM) as Special Flood Hazard Areas (SFHA). SFHA are defined as areas that will be inundated by the flood event having a 1-percent chance of being equaled or exceeded in any given year, and are normally called 100-year floodplains. The 1-percent annual chance flood is also referred as the 100-year flood. The area subject to a 0.2 percent chance of flooding in any given year is normally called the 500-year floodplain.
As a federal agency, TVA adheres to the requirements of EO 11988, Floodplain Management. The objective of EO 11988 is “to avoid to the extent possible the long- and short-term adverse impacts associated with the occupancy and modification of floodplains and to avoid direct and indirect support of floodplain development wherever there is a practicable alternative” (EO 11988, Floodplain Management). The EO is not intended to prohibit floodplain development in all cases, but rather to create a consistent government policy against such development under most circumstances (U.S. Water Resources Council, 1978). The EO requires that agencies avoid the 100-year floodplain unless there is no practicable alternative.
Figure 3.13 Proposed Horus Kentucky Solar Project Site FEMA FIRM Map
Based on Simpson County, Kentucky, flood insurance rate map (FIRM) Panel number 21213C0195C, effective 3/17/2011, the entirety of the Project Site is located outside 100- year floodplains.
Draft Environmental Assessment 49 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences
Based on Sumner County, Tennessee, FIRM Panel numbers 47165C0025G, 47165C0132G, 47165C0134G, 47165C0175G, 47165C0434G, and 47165C0442G, all effective 4/17/2012, portions of the northern section of the Project Transmission Line Upgrades are located within 100-year floodplains.
Based on Wilson County, Tennessee, FIRM Panel numbers 47189C0045E, effective 5/18/2009; and 47189C0152D, 47189C0153D, 47189C0154D, and 47189C0156D, all effective 2/20/2008, portions of the southern section of the Project Transmission Line Upgrades are located within 100-year floodplains.
Environmental Consequences
No Action Alternative Under the No Action Alternative, the Project Site would not be constructed; therefore, no Project-related impacts to floodplains would be expected to occur.
Proposed Action Alternative The Project Site would be entirely located outside 100-year floodplains, which would be consistent with EO 11988. A portion of the Project Transmission Line Upgrades would be located within 100-year floodplains. The transmission lines are existing. Work would consist of replacing existing poles or modifying transmission equipment located on existing poles. Replacing poles would be considered a repetitive action within the 100-year floodplain, which would be consistent with EO 11988. Transmission line access roads have not yet been determined, and will be addressed in a future environmental review. However, in general, access roads are considered to be repetitive actions in the 100-year floodplain that should result in minor impacts.
By implementing the following mitigation measures, the proposed solar project and Project Transmission Line Upgrades would have no significant impact on floodplains and their natural and beneficial values: o Standard BMPs would be used during construction activities. o Non-recyclable and/or non-reusable material remaining following development of the Project Site would be disposed of at a location outside 100-year floodways.
Additionally, the amount of potential fill required to grade the Project Site would be negligible and should not impact any adjacent properties with respect to flooding frequency or intensity. Although minimal grading and fill could be necessary to construct the Project, no indirect impacts to floodplains associated with construction and operation of the Project Site would be anticipated.
3.4 Biological Resources This section describes the existing biological resources within the Project Area and the potential impacts on these biological resources that would be associated with the No Action and Proposed Action Alternatives. Components of biological resources that are analyzed include vegetation, wildlife, threatened and endangered and other rare species.
3.4.1 Vegetation
Affected Environment The Project Site predominantly consisted of row crop agricultural land, and with a small forested area located in the southeastern portion of the Project Site and a low-lying
Draft Environmental Assessment 50 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences wooded/shrubby area in the eastern-central portion of the Project Site. The dominant plant species observed in the row crop agricultural upland portions of the Project Site were remnants of corn (Zea mays) and soybeans (Glycine max). The dominant plant species observed in the forested uplands of the Project Area were black walnut (Juglans nigra), red maple (Acer rubrum), white grass (Leersia virginica), amur honeysuckle (Lonicera maackii), tulip poplar (Liriodendron tulipifera), shagbark hickory (Carya ovata), and hackberry (Celtis occidentalis). Lastly, the dominant plant species observed in the emergent wetlands in the Project Area were phragmites (Phragmites australis), cattail (Typha angustifolia), box elder (Acer negundo) saplings, and Virginia whitegrass (Leersia virginica).
Environmental Consequences
No Action Alternative Under the No Action Alternative, the Project Site would not be constructed; therefore, no Project-related impacts to vegetation would be expected to occur. Existing land use would remain as farmland and vegetation would remain as they are at the present time.
Proposed Action Alternative Under the Proposed Action Alternative, the Project Site would be constructed which would lead to the conversion of actively cultivated agricultural vegetation to native or non-invasive vegetation. Although a small forested area is located in the southeastern portion of the Project Site, no tree clearing is proposed during construction or operation of the Project Site. Construction activities have the potential to temporarily affect storm water runoff, which could result in temporary disturbances that affect surrounding plant and environment interactions. These disturbances have the potential for invasive species to rapidly spread and displace native vegetation; however, these activities would be managed under the implementation of a SWPPP and BMPs. Revegetation using non-invasive native plants and seed mixtures would be required. Proper implementation of BMPs would result in only minor temporary impacts to plant species onsite and immediately adjacent. Upon completion of construction, the Project Site would establish low-growing native species. The conversion of agricultural crops to native or non-invasive species would result in long-term benefit to the vegetation community within the Project Site.
Limited amount of ground disturbance would occur along discrete locations along the Project Transmission Line Upgrades, where new poles would be installed, or existing poles would be replaced. Seasonal surveys for rare plant communities are currently ongoing. Appropriate avoidance an minimization measures would be used if rare vegetative communities are identified in areas of proposed actions. Areas within the existing ROW that are currently in cultivation would continue to be cultivated post-construction. Disturbed areas outside of actively cultivated areas would be re-seeded as necessary to prevent erosion within the ROW. Additional environmental review would occur when proposed access roads have been identified. With the use of BMPs and avoidance and minimization measures, proposed actions would not significantly impact vegetative communities.
2.5.2 Wildlife
Affected Environment Wildlife occurring within the Project Area includes mammals, reptiles, and birds commonly native to all areas in the State of Kentucky and Tennessee. Edge species and species associated with active agriculture and old field habitats include rodents and other small mammals, deer, turkey, songbirds, and raptors.
Draft Environmental Assessment 51 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences
Mammals commonly found throughout both states include coyotes (Canis latrans), white- tailed deer (Odocoileus virginianus), gray fox (Urocyon cinereoargenteus), beavers (Castor canadensis), skunks (Mephitis mephitis), opossums (Didelphis virginiana), racoons (Procyon lotor), squirrels (Sciurus spp.), bobcat (Lynx rufus), and armadillos (Dasypus novemcinctus). In addition, reptiles and amphibians commonly found in the region include a variety of turtles, lizards, frogs, and snakes. Fence lizards (Sceloperus spp.), five-lined skinks (Plesitiodon fasciatus), and broad-headed skink (Plestiodon laticeps) are commonly observed lizards. Gray tree frog (Hyla versicolor), cricket frog (Acris gryllus), green tree frog (Hyla cinerea), bullfrog (Lithobates catesbeianus), American toad (Anaxyrus americanus), eastern spadefoot toad (Scaphiopus holbrookii), marbled salamander (Ambystoma opacum), and spotted salamander (Ambystoma maculatum) are often observed in the region. Non-venomous snakes include garter snake (Thamnophis sirtalis), black king snake and speckled kingsnake (Lampropeltis spp.), rat snake (Pantherophis spp.), and water snake (Nerodia spp.), while venomous species include cottonmouth (Agkistrodon piscivorus), copperhead (Agkistrodon contortrix), pygmy rattlesnake (Sistrurus miliarius), and timber rattlesnake (Crotalus horridus). Birds common to the region include mourning dove (Zenaida macroura), blue jay (Cyanocitta cristata), American crow (Corvus brachyrhynchos), barn swallow (Hirundo rustica), Carolina wren (Thyrothorus ludovicianus), eastern bluebird (Sialia sialis), American robin (Turdus migratorius), European starling (Sturnus vulgaris), northern cardinal (Cardinalis cardinalis), field sparrow (Spizella pusilla), indigo bunting (Passerina cyanea), red-tailed hawk (Buteo jamaicensis), black vulture (Coragyps atratus), and turkey vulture (Cathartes aura).
Surveys for protected species and habitat assessments were conducted and are provided in Appendix C. Areas within the Project Site that are not currently used for agriculture would provide suitable habitat for wildlife common to the region both seasonally and year-round.
Review of the TVA Regional Natural Heritage Database (NHD) in April 2021 indicated the following records:
o Records of 8 osprey nests, 2 wading bird colony nests, and 4 caves within 3 miles of the Project Site.
Field surveys did not identify any osprey nests or wading bird colonies within potential areas of impact. One 15 foot deep vertical cave was identified in the Project Site during field reviews.
Environmental Consequences
No Action Alternative Under the No Action Alternative, the Project Site would not be constructed; therefore, no Project-related impacts to wildlife would be expected to occur. Existing land use would remain as farmland and wildlife would remain as they are at the present time.
Proposed Action Alternative The Project would include installation of security fencing around the perimeter of the Project Site. The fencing would deter deer and other large migrating animals from entering the Project Site, while allowing for movement of small animals such as reptiles, amphibians, and small mammals. Although the Project Site would include installation of multiple rows of PV panels on supporting structures, transition from row crows to native species and the resulting
Draft Environmental Assessment 52 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences change in land management would provide a long-term benefit to small animals such as song birds, reptiles, amphibians, and small mammals. Post-construction land management strategies would no longer involve active broad pesticide and herbicide application not frequent and on-going land disturbance activities associated with agricultural production. Per Figure 2.4 – Proposed Horus Kentucky Solar Project Site Layout, the development of the Project Site incorporates the karst avoidance areas based on the results of the field survey and subsurface exploration. Therefore, identified karst features and caves would be avoided for the construction of the Project Site. In addition, identified streams and wetlands would also be avoided as part of the Project Site development. In addition, a 50-foot buffer would be maintained from the identified caves, karst features, streams, and wetlands to avoid any direct impacts to these features. Although a small forested area is located in the southeastern portion of the Project Site, no tree clearing is proposed during construction or operation of the Project Site. All other known osprey nests or heronries are far enough away such that no impacts would occur. Additional environmental review would occur once access roads have been identified.
Due to successional and herbaceous composition of habitat within the existing ROW and Project Site, it is expected that wildlife currently utilizing the existing habitat would be able to relocate successfully to nearby areas of similar habitat and food sources during construction. Therefore, during the Project Area construction, temporary, negligible impacts to wildlife would be anticipated. Once construction is complete, wildlife would return to the Project Area as construction equipment and workers demobilize.
2.5.3 Threatened & Endangered and Other Rare Species
Affected Environment A review of species extracted from the TVA NHD and USFWS Information for Planning and Consultation (IPaC), and Office of Kentucky Natural Preserves (OKNP) for threatened, endangered, and candidate species for the Project Site and Simpson County, Kentucky is presented below in Table 3.10.
Table 3.10 TVA Natural Heritage Database information for state and federally- listed species within a 10-mile search radius of the Project Site and within the counties in which the Project Site is located
Habitat Scientific Name Common County State State State Federal Habitat Name Rank Status Status Observed Aquatic Villosa ortmanni Kentucky Simpson KY S1, E - No Creekshell S2 Aquatic Etheostoma Splendid Sumner TN S3 D - No barrenense Darter Aquatic Carychium Cave Thorn Sumner TN S2 - - No stygium Aquatic Etheostoma Orangefin Sumner TN S3 D - No bellum Darter Aquatic Etheostoma Teardrop Sumner TN S2 D - No barbouri Darter Aquatic Typhlichthys Southern Simpson KY S2, - - No subterraneus Cavefish S3 Aquatic Orconectes Mammoth Simpson KY S3 S - No pellucidus Cave Crayfish Aquatic Percina Frecklebelly Sumner TN S1 D - No stictogaster Darter Aquatic Villosa Mountain Simpson KY S2 T - No vanuxemensis Creekshell
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Aquatic Percina Longhead Allen KY S1 E - No macrocephala Darter Aquatic Barbicambarus Bottlebrush Simpson KY S2, S - No cornutus Cra yfi sh S3 Aquatic Cryptobranchus Eastern Simpson KY S2S3 S PS:PE No alleganiensis Hellbender Terrestrial Spiranthes Sweetscent Sumner TN S1 E - No odorata Ladies'-tre sse s Terrestrial Hypericum Creeping St. Sumner TN S1 E - No adpressum John's-wort Terrestrial Batriasymmodes Cave-Obligate Simpson KY SH H - No quisnamus Beetle Terrestrial Myotis grisescens Gray Bat Robertson, TN S2 E LE Foraging Sumner Terrestrial Myotis grisescens Gray Bat Simpson KY S2 T LE Foraging
Terrestrial Perimyotis Tricolored Bat Robertson TN S2S3 T - Yes subflavus
The aquatic habitat observed on the Project Site consisted of small, low quality ephemeral channels that terminated into karst features and a low-quality, isolated wetland that appears to be a filled-in agricultural pond. Based on the characteristics of these aquatic features, suitable habitat for the aquatic species listed in the NHD were not observed at the Project Site. With the exception of bats, habitat for the remaining terrestrial species above were not observed within the Project Site. The Tri-Colored bat (Perimyotis subflavus) typically hibernates in caves and/or mines and forages in open, forested habitat during the summer. Both gray bat and tricolored bat forage over streams and wetlands. Based on observations made during the site reconnaissance, hibernacula for tricolored bat and suitable foraging habitat for tricolored bat and gray bat is present on the southeastern portion of the Project Site.
Table 3.11 TVA Natural Heritage Database information for state and federally- listed aquatic species within a 10-mile search radius and terrestrial species within the counties in which the Project Transmission Line Upgrades are located
Habitat Scientific Name Common Name County State State State Federal Habitat Rank Status Status Observed Aquatic Barbicambarus Bottlebrush Simpson KY S2, S - No cornutus Cra yfi sh S3 Aquatic Carychium stygium Cave Thorn Sumner TN S2 - - No Aquatic Etheostoma Teardrop Darter Sumner TN S2 D - No barbouri Aquatic Etheostoma Splendid Darter Sumner TN S3 D - Potential barrenense Aquatic Etheostoma Orangefin Darter Sumner TN S3 D - No bellum Aquatic Hemitremia Flame Chub Simpson KY S1 E - f l a mme a Aquatic Orconectes Mammoth Cave Simpson KY S3 S - No pellucidus Cra yfi sh Aquatic Percina Longhead Allen KY S1 E - No macrocephala Darter Aquatic Percina Frecklebelly Sumner TN S1 D - No stictogaster Darter Aquatic Rabdotus Whitewashed Warren KY S1, T - No dealbatus Rabdotus S2 Aquatic Typhlichthys Southern Simpson KY S2, - - Potential subterraneus Cavefish S3 Aquatic Villosa ortmanni Kentucky Simpson KY S1, E - No Creekshell S2 Aquatic Villosa Mountain Simpson KY S2 T - No vanuxemensis Creekshell
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Terrestrial Batriasymmodes Cave-Obligate Simpson KY SH H - No quisnamus Beetle Terrestrial Cryptobranchus Eastern Simpson KY S2, S PS:PE No alleganiensis Hellbender S3 Terrestrial Cryptobranchus Eastern Sumner TN S3 E PS No alleganiensis Hellbender Terrestrial Dalea foliosa Leafy Prairie- Sumner TN S2S3 E E Potential Clover Terrestrial Haliaeetus Bald Eagle Sumner TN S3 D DM Foraging leucocephalus Terrestrial Hypericum Creeping St. Sumner TN S1 E - Potential adpressum John's-Wort Terrestrial Myotis grisescens Gray Bat Robertson, TN S2 E LE Foraging Sumner Terrestrial Myotis grisescens Gray Bat Simpson KY S2 T LE Foraging
Terrestrial Myotis Northern Long- Sumner TN S1S2 T - Foraging septentrionalis eared Bat Terrestrial Perimyotis Tricolored Bat Robertson TN S2, T - YES subflavus S3 Terrestrial Spiranthes odorata Sweetscent Sumner TN S1 E - Potential Ladies'-T re sse s Terrestrial Zapus hudsonius Meadow Sumner TN S4 - PS Yes Jumping Mouse Terrestrial Neotoma magister Allegheny Wilson TN S3 - - Yes Woodrat
The aquatic habitat observed within the Project Transmission Line Upgrades ranged from small, low quality ephemeral channels to large perennial channels such as West Fork Drakes Creek and the Cumberland River. Several ponds and ephemeral and shrub-scrub wetlands were observed in the Project Transmission Line Upgrades. None of the listed species were observed during the site reconnaissance. Based on the characteristics of these aquatic features, suitable habitat for several of the aquatic species listed in the NHD is present in the Project Transmission Line Upgrades. Presence of the above-mentioned aquatic species are assumed, and appropriate avoidance measures would be implemented.
The terrestrial habitat observed within the Project Transmission Line Upgrades ranged from open successional field, shrub land and marshy wetlands and wet meadows. None of the listed species were observed during the initial site reconnaissance. Based on the characteristics of these terrestrial features, suitable habitat for several of the species listed in the NHD is present within the Project Transmission Line Upgrades. See additional descriptions below for federally listed or federally protected species.
The OKNP listed the following species to potentially occur within the Project Area, which are discussed below:
The Eastern hellbender (Cryptobranchus alleganiensis) is an amphibian species listed as imperiled and vulnerable in the state of Kentucky. This species is typically confined to running water in large streams and rivers. Suitable habitat for this species was not observed on the Project Site. The Loggerhead shrike (Lanius ludovicianus) is an avian species listed as vulnerable to secure in the state of Kentucky and identified as occurring in the northeastern section of the Franklin, KY USGS 7.5’ Topographic Quadrangle. This species is typically found in areas of low vegetation with interspersed short trees/shrubs and/or fences for perches. Suitable habitat for this species was not observed on the Project Site.
Another species of concern that may occur in areas of proposed Project Transmission Line Upgrades is the streamside salamander (Ambystoma barbouri). Three known records of Streamside salamanders within 3 miles of the Project Transmission Line Upgrades, all within
Draft Environmental Assessment 55 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences tributaries of Spencer creek (with the closest record located at 1.1 miles from the Project Area). Wet weather conveyances and intermittent streams occur along segments of ROW with proposed upgrades. Seasonal surveys would occur areas of proposed impact for the upgrades and access roads.
Federally-Listed Species The USFWS IPaC listed the following species to potentially occur within the Project Site, which are discussed below: The Indiana bat (Myotis sodalis) is a federally-listed endangered species and the Northern long-eared bat (Myotis septentrionalis) is a federally-listed threatened species, both known to occur in Simpson County, Kentucky. Potential summer roosting habitat for these species generally consists of sites that contain mature and/or standing dead trees with exfoliating bark, and/or stream/river corridors which serve as flight paths. Additionally, sites that contain caves could be used by the Indiana bat and Northern long-eared bat for winter hibernacula. Karst features were observed on the Project Site. The deepest karst sinkhole observed on the project site was approximately 15 feet deep and nearly vertical in structure. The interior of the aforementioned sinkhole was observed, and horizontal space that would accommodate Indiana and/or Northern long-eared bat hibernacula was not observed. A small forested area containing mature trees with features that could be used for summer bat roosting and with a relatively open understory were observed in the southeastern portion of the Project Site. Additionally, two tree lines on the western portion of the project site contained potential roost trees (PRTs). Therefore, potential summer habitat was identified on the Project Site. Suitable foraging habitat occurs over forested areas and streams and wetlands. No known captures or hibernacula records of Indiana bat occur within 10 miles of the Project Area. No Northern Long-Eared Bat records are known within 5 miles of the Project Area. The closest known Indiana Bat maternity roosts is located in Wilson County, Tennessee, approximately 14 miles away from the Project Area. The closest known Northern Long-Eared Bat hibernacula is located approximately 14.6 miles away from the Project Area.
The Gray bat (Myotis grisescens) is a federally-listed endangered species known to occur in Simpson County, Kentucky. The Gray bat typically lives in caves year-round and forages over streams, wetlands, and ponds. The closest known Gray bat hibernaculum is located approximately 0.8 miles from the Project Area. Numerous karst features were observed on the Project Site. The deepest karst sinkhole observed on the Project Site was approximately 15 feet deep and nearly vertical in structure. Based on observation of the interior of the aforementioned sinkhole, and horizontal space that would accommodate Gray bat roosting and use was not observed. Based on the observations made during the site reconnaissance foraging habitat is present on the Project Site.
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Figure 3.14 Proposed Horus Kentucky Solar Project Site Habitat Type s M ap
Figure 3.15 Representative Photograph of Forested Area within Proposed Horus Kentucky Solar Project Site
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The Snuffbox mussel (Epioblasma triquetra) is a federally-listed endangered species listed as occurring in Simpson County, Kentucky. Snuffbox mussels are found in small to medium- sized creeks and in larger rivers and lakes. In addition, they are found in swift currents of riffles and shoals and along wave-washed lakeshores over gravel and sand with cobble and boulders. The aquatic habitat observed on the Project Site consisted of ephemeral channels terminating in karst features and without downstream connections and an isolated wetland; therefore, the potential habitat for this species is not present on the Project Site.
The USFWS IPaC listed the following species to potentially occur within the Project Transmission Line Upgrades, which are discussed below:
Suitable hibernacula for gray bat, Indiana bat, and northern long-eared bat does not occur in areas of proposed upgrades. However suitable foraging for all three species does occur over bodies of water and along forested edges in areas of proposed upgrades.
The Cumberlandian Combshell (Epioblasma brevidens) is a species that inhabits medium- sized streams to large rivers with shoals and riffles in coarse sand, gravel, cobble, and boulders. This species is not associated with small streams. The Dromedary Pearlymussel (Dromus dromas) is a species that inhabits small to medium, low turbidity, high to moderate gradient streams. The species is commonly found near riffles on sand and gravel substrates with stable rubble. The Fanshell (Cyprogenia stegaria) is a mussel that is found in medium to large rivers. It buries itself in sand or gravel in deep water of moderate current, with only the edge of its shell and its feeding siphons exposed. The Orangefoot Pimpleback (pearlymussel) (Plethobasus cooperianus) is a species that is typically found in medium to large rivers. The Pink Mucket (pearlymussel) (Lampsilis abrupta) is a species is typically found in mud and sand substrate and shallow riffles, with relatively low amounts of silt, of major rivers and tributaries. The Purple Cat's Paw (Epioblasma obliquata obliquata) is a species that is typically found in shallow waters of silt-free gravel and sandy substrates of larger rivers. The Ring Pink (mussel) (Obovaria retusa) is a species that is typically found in shallow waters of silt-free gravel and sandy substrates of larger rivers. The Rough Pigtoe (Pleurobema plenum) is a species that is typically found in a wide variety of stream sizes in a mixed substrate of clean silt, sand, and gravel. The Snuffbox mussel (Epioblasma triquetra) is a species that is typically found in small to medium-sized creeks in areas of swift currents, most often in sand, gravel, and/or cobble substrates. The Tubercled Blossom (pearlymussel) (Epioblasma torulosa torulosa) is a species that is typically found in shallow sand and gravel shoals in large rivers with swift currents. The White Wartyback (pearlymussel) (Plethobasus cicatricosus) is a species that is typically found in clean, fast flowing water with sand and gravel bottoms of large rivers. The aquatic habitat observed within the Project Transmission Line Upgrades ranged from small, low quality ephemeral channels to large perennial channels such as West Fork Drakes Creek and the Cumberland River. Based on the characteristics of these aquatic features, suitable habitat for the listed clam species is present within the Project Transmission Line Upgrades. Presence of the above-mentioned aquatic species are assumed, and appropriate avoidance measures would be implemented.
The Braun's Rock-cress (Arabis perstellata) is a federally-listed endangered species potentially occurring in Sumner and/or Wilson Counties, Tennessee. According to NatureServe Explorer this species is often “…found on mesic, shady, steep, north-facing wooded slopes” or “in sheltered areas, such as around the bases of larger trees, or in areas where there is little competition…” Based on the absence of trees beyond early sapling stage and the high amount of herbaceous competition along the majority of the Project
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Transmission Line Upgrades, neither this species nor its habitat are present within the Project Transmission Line Upgrades.
The Leafy Prairie-clover (Dalea foliosa) is a federally-listed endangered species potentially occurring in Sumner and/or Wilson Counties, Tennessee. According to NatureServe Explorer, this species prefers “open, thin-soiled limestone glades and moist prairies, near streams or limestone seeps. Habitat with these characteristics was observed in various areas within the Project Transmission Line Upgrades, with the highest concentration between the Cumberland River and the intersection of Coles Ferry Road and Academy Road. Individuals of this species were not observed during the site reconnaissance. Additional surveys for this species are ongoing along L5775 of the Project Transmission Line Upgrades.
The Spring Creek Bladderpod (Lesquerella perforata) is a federally-listed endangered species known to occur in the floodplain of two creeks in Wilson County, Tennessee. According to NatureServe Explorer, this species is found on flood plains where disturbances limit encroachment and competition from woody species and grasses. Based on the presence of multiple streams, some with associated wetlands, and all with disturbance from ROW maintenance and/or other management by land owners/managers along the ROW in Wilson County, habitat for this species may be present within the Project Transmission Line Upgrades. Individuals of this species were not observed during the initial site reconnaissance. Additional surveys for this species are ongoing along L5775 of the Project Transmission Line Upgrades. .
Bald Eagles and Migratory Birds The bald eagle is protected under the Bald and Golden Eagle Protection Act (BGEPA) and the Migratory Bird Protection Act (MBTA). This avian species is typically found in the vicinity of large water features and nests in tall trees or cliffs near waterways. Nesting habitat was not observed on the Project Area; however, foraging habit may be present along the Project Transmission Line Upgrades at West Fork Drakes Creek and the Cumberland River. While there are records of osprey nests and wading bird colony nests on structures immediately adjacent to the Project Transmission Line Upgrades on either side of the Cumberland River, no bald eagles, ospreys, or nests were observed during the environmental field surveys within the Project Area or along public roadways near the Project Area. In addition, review of the USFWS IPaC did not result in the identification of any migratory bird species of conservation concern that have the potential to occur in the Project Area.
Environmental Consequences
No Action Alternative Under the No Action Alternative, the Project Site would not be constructed; therefore, no Project-related impacts to Federal or state threatened, and endangered species would occur.
Proposed Action Alternative Suitable habitat for state-listed species including Allegheny woodrat and meadow jumping mouse was observed in the Project Area. Due the avoidance of cave and karst features, Allegheny woodrat is not likely to be impacted. Any habitat fragments for meadow jumping mouse that may occur along proposed transmission line upgrades may be impacted by proposed actions. However, due to the small isolated areas of impact along the transmission lines, populations of meadow jumping mouse would not be impacted. Additional surveys for streamside salamander on L5775 would occur when seasonally appropriate. If populations
Draft Environmental Assessment 59 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences of the species occur in areas of proposed impact, state agencies would be contacted and appropriate avoidance and minimization measures would be put in place.
While suitable summer roosting and/or foraging habitat for the Indiana bats, Northern long- eared bats, and Tricolored bats is present on the Project Site, tree clearing is not proposed within the Project Site, so there would be no direct impacts to the listed bat species. Per Figure 2.4 – Proposed Horus Kentucky Solar Project Site Layout, the development of the Project Site incorporates the karst avoidance areas based on the results of the field survey and subsurface exploration. Therefore, identified karst features and caves that could offer hibernacula for tricolored bat would be avoided for the construction of the Project Site. In addition, identified streams and wetlands are also being avoided as part of the Project Site development. In addition, a 50-foot buffer would be maintained from the identified caves, karst features, streams, and wetlands to avoid any direct impacts to these features. Therefore impacts to foraging habitat for these bat species as well as gray bat would be minimized or avoided on the Project Site.
No tree clearing is proposed for the Project Transmission Line Upgrades therefore no impacts for summer roosting habitat for Indiana Northern, and tricolored bats would occur. Avoidance and minimization measures used along wetlands and streams near upgrades would result in avoidance or minimization of impacts to potential foraging habitat for bats.
During environmental field surveys, no bald eagles, ospreys, or nests were observed in or adjacent to the Project Area. Therefore, the Proposed Action Alternative is in compliance with the National Bald Eagle Management Guidelines. After construction, the native or noninvasive vegetation and lack of herbicides or pesticides may increase foraging areas for songbirds and potential nesting sites for ground nesters.
Additional surveys are currently on-going for the Leafy Prairie Clover and Spring Creek Bladderpod along L5775 of the Project Transmission Line Upgrades. If appropriate, TVA would consult with the U.S. Fish and Wildlife Services (USFWS) under Section 7 of the Endangered Species Act. Avoidance and minimization measures would be used to ensure no significant impacts to federal or state-listed species would occur.
3.5 Cultural Resources This section describes the existing cultural resources within the Project Area and the potential impacts on these cultural resources that would be associated with the No Action and Proposed Action Alternatives. Components of cultural resources that are analyzed include prehistoric and historic archaeological and architectural resources. It should be noted that no architectural survey was required along the Proposed Transmission Line Upgrades within Kentucky and Tennessee as any height change of the transmission lines are proposed to be no greater than 7–10 feet in height from the existing infrastructure.
Affected Environment Cultural resources are properties and places that illustrate aspects of prehistory or history or have long-standing cultural associations with established communities and/or social groups. Cultural resources may include archaeological sites, unmodified landscapes and discrete natural features, modified landscapes, human-made objects, structures such as bridges, buildings, and groups of any of these resources, sometimes referred to as districts. Section
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106 of the National Historic Preservation Act (NHPA), as amended (54 U.S.C. § 300101 et seq.) is specifically designed to address the effects of federal and/or federally funded projects on tangible cultural resources—that is, physically concrete properties—of historic value. The NHPA provided for a national program to support both public and private efforts to identify, evaluate, and protect the nation’s important cultural resources. Once identified, these resources are evaluated for inclusion in the National Register of Historic Places (NRHP) maintained by the National Park Service. Tangible cultural resources may qualify for inclusion in the NRHP if they are 50 years of age or older (unless in exceptional cases) and if found to embody one or more of four different types of values, or criteria, in accordance with 36 CFR § 60.4:
o Criterion A: association with events that have made a significant contribution to the broad patterns of our history. Such events may include a specific occurrence or pattern of occurrences, cultural traditions, or historic trends important at a local, regional, or national level. To be considered in association with a cultural resource, events must be important within the particular context being assessed. o Criterion B: association with the lives of persons significant in our past. People considered may be important locally, regionally, or nationally, and the cultural resources considered are limited to properties illustrating a person’s achievements rather than commemorating them. o Criterion C: embodiment of the distinctive characteristics of a type, period, or method of construction; representative of the work of a master; possessing high artistic values; or representative of a significant and distinguishable entity whose components may lack individual distinction. Cultural resources considered generally include architectural resources such as buildings, objects, districts, and designed landscapes. o Criterion D: cultural resources that have yielded, or may be likely to yield, information important in prehistory or history. Considered cultural resources typically include archaeological sites but may also include buildings, structures, and objects if they are the principal source of important information not contained elsewhere.
Cultural resources that are listed or considered eligible for listing on the NRHP are called “historic properties.” Federal agencies are required by the NHPA to consider the possible effects of their undertakings on historic properties and take measures to avoid, minimize, or mitigate any adverse effects. NEPA requires federal agencies to consider how their undertakings may affect the quality of the human environment, including both cultural resources and those defined as historic properties, so that the nation may “preserve important historic, cultural, and natural aspects of our national heritage.” “Undertaking” includes any project, activity, or program that has the potential to have an effect on a historic property and that is under the direct or indirect jurisdiction of a federal agency or is licensed or assisted by a federal agency. Considering an undertaking’s possible effects on historic properties is accomplished through a four-step review process outlined in Section 106 of the NHPA (36 CFR § 800). These steps are:
1. Initiation (defining the undertaking and the Area of Potential Effect [APE] and identifying the parties to be consulted in the process); 2. Identification (studies to determine whether cultural resources are present in the APE and whether they qualify as historic properties); 3. Assessment of adverse effects (determining whether the undertaking would affect the qualities that make the property eligible for the NRHP); and 4. Resolution of any adverse effects (by avoidance, minimization, or mitigation).
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A resource may be eligible under one or more of these criteria. Criteria A, B, and C are most frequently applied to historic buildings, structures, objects, non-archaeological sites (e.g., battlefields, cemeteries, natural features, and designed landscapes), or districts. Also, a general guide of 50 years of age is used to define “historic” in the NRHP evaluation process. A resource may, however, be eligible for the National Register even if it is less than 50 years of age but has exceptional significance. The most frequently used criterion for assessing the significance of an archaeological site is Criterion D, although other criteria were considered where appropriate. For an archaeological site to be considered significant, it must have potential to add to the understanding of the area's history or prehistory. A commonly used standard to determine a site's research potential is based on a number of characteristics including artifact variety and quantity, site integrity, clarity, and environmental context. Another important factor is the uniqueness of the site. Sites that are commonly found should exhibit exceptional integrity and research potential to be eligible for inclusion in the NRHP. Site types that are rarely found (e.g., Clovis Period sites), or those that have strong cultural significance to descendant populations (e.g., burial mounds), may have less stringent technical requirements for inclusion in the NRHP.
Additional cultural resource laws that protect historic resources include the Archaeological and Historic Preservation Act (16 USC 469-469c), Archaeological Resources Protection Act (16 USC 470aa-470mm) and the Native American Graves Protection and Repatriation Act (25 USC 3001-3013). Throughout the process, the lead federal agency must consult with the appropriate State Historic Preservation Officer (SHPO), federally recognized American Indian tribes that have an interest in the undertaking, and any other party with a vested interest in the undertaking. Through various regulations and guidelines, federal agencies are encouraged to coordinate Section 106 and NEPA review to improve efficiency and allow for more informed decisions. Under NEPA, impacts to cultural resources that are part of the affected human environment but not necessarily eligible for the NRHP must also be considered by federal agencies. Generally, these considerations are accomplished through consultation with parties having a vested interest in the undertaking, as described above. A project may have effects on a historic property that are not adverse, if those effects do not diminish the qualities of the property that identify it as eligible for listing on the NRHP. However, if the agency determines (in consultation with the SHPO and other parties) that the undertaking’s effect on a historic property within the area of potential APE would diminish any of the qualities that make the property eligible for the NRHP (based on the criteria for evaluation at 36 CFR Part 60.4 above), the effect is said to be adverse. Examples of adverse effects would be ground-disturbing activity in an archaeological site or erecting structures within the viewshed of a historic building in such a way as to diminish the structure’s integrity of feeling or setting.
Federal agencies must resolve the adverse effects of their undertakings on historic properties. Resolution may consist of avoidance (such as choosing a project alternative that does not result in adverse effects), minimization (such as redesign to lessen the effects), or mitigation. Adverse effects to archaeological sites are typically mitigated by means of excavation to recover the important scientific information contained within the site. Mitigation of adverse effects to historic structures sometimes involves thorough documentation of the structure by compiling historic records, studies and photographs. Agencies are required to consult with SHPOs, tribes and others throughout the Section 106 process and to document adverse effects to historic properties resulting from agency undertakings.
As part of the evaluation process, an archaeological survey (of the Project Area) and a separate architectural survey (of Project Site only) were conducted in May, October,
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November, December 2020 and January 2021 to determine the presence of prehistoric and historic cultural resources that are listed or eligible for listing in the NRHP (Attachment D). The Section 106 review process commences with the delineation of the project’s area of potential effect (APE). The 550-acre Project Site and approximately 20.96 miles of existing TVA Transmission Lines L5402 and L5775 (100-foot wide survey corridor) comprises the APE for cultural resources. Two APEs were defined for the Proposed Action: a direct effects APE and an indirect effects APE. The direct effects APE is defined as the area that would be directly affected by potential Project construction, clearing, and operations. The direct effects APE overlaps with the Project Area and consists of the Project Site and Project Transmission Line Upgrades. The indirect effects APE is defined as a 0.5-mile radius surrounding the Project Site. The Project Area and a 0.5-mile radius surrounding the tract were evaluated during background research. The cultural resources assessment for the direct and indirect effects APEs consisted of background research, field surveys, archaeological analysis, initial NRHP evaluations, and results summary.
Architectural Resources Desktop and field analyses were completed regarding the Proposed Action’s potential to affect historic properties. The purpose of the analyses was to identify previously recorded historic architectural resources within the APE, which was defined to include a 0.5-mile buffer surrounding the proposed fence line of the Project Site. The review included an analysis of historical aerial imagery and topographic quadrangles, a review of the files maintained by the Kentucky Heritage Council, and a review of the NRHP and National Historic Landmark databases maintained by the National Park Service. Information on known historic architectural resources occurring in or near the APE was examined, as well as previously completed cultural resources reports and historic documents pertinent to the APE.
As a result of the investigations, 26 resources were identified. Two resources, SI 520 and SI 526, were unable to be evaluated due to their distance from the right-of-way or publicly accessible roads. Resource SI 526 is separated by I-65 and a wooded area from the project and the Project Site would not be visible from the resource. Resource No. SI 520 is separated from the project area by open fields and the proposed solar farm would be visible. Because Resource SI 520 could not be evaluated and could be visually impacted, vegetative screening is recommended to shield the resource and minimize potential adverse effects. The remainder of the APE contains no significant above-ground historic resources and no additional work is recommended.
Archaeological Resources As the Project Area goes into Kentucky and Tennessee, background research for the Project Area was obtained from both the Kentucky Historical Commission (KHC) and the Kentucky Office of State Archaeology (OSA) and the Tennessee Division of Archaeology (TDOA).
Kentucky Fieldwork for the Phase I Archaeological Survey was conducted in five intermittent sessions between May 26, 2020, and April 28, 2021. In total, 1,165 shovel tests were excavated within the Project Area. As a result of the archaeological investigations, one previously recorded site, 15Si17, four newly recorded sites—15Si60, 15Si62, 15Si61, and 15Si63—six isolated finds (IFs 1–6) and one small family cemetery (Kitchens Cemetery, 15Si64/ KHC number SI 536) were identified. Previously recorded archaeological sites 15Si31 and 15Si327, reported to be in or near the project, were not re-located.
Tennessee
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During the survey of TL L5402, a total of 216 shovel tests was excavated along a single transect placed in the center of transmission line. During the survey, no archaeological sites were identified. As a result of the investigations, two Precontact isolated finds (IF-1 and IF-2) and the Williams Family Cemetery were identified. All three resources are recommended as being ineligible for inclusion in the NRHP. Based on these results, no historic properties would be affected by the proposed undertaking and no further cultural resources work should be necessary. To comply with Tennessee State Law, however, the Williams Cemetery should be avoided by any ground disturbing activities.
Environmental Consequences
No Action Alternative Under the No Action Alternative, the Project Site would not be constructed; therefore, no Project-related impacts to cultural resources would occur.
Proposed Action Alternative It should be noted that no architectural survey was required along the Proposed Transmission Line Upgrades within Kentucky and Tennessee as any height change of the transmission lines are proposed to be no greater than 7–10 feet in height from the existing infrastructure.
As a result of the architectural survey of the Project Site, 26 resources were identified. The Project would include installation of a privacy fence and vegetative screening buffer that would be placed along Project boundaries (where existing natural buffers are not sufficient in shielding adjacent residents). The remainder of the APE contains no significant above- ground historic resources and no additional work is recommended.
As a result of the archaeological investigations within Kentucky, one previously recorded site, 15Si17, four newly recorded sites—15Si60, 15Si62, 15Si61, and 15Si63—six isolated finds (IFs 1–6) and one small family cemetery (Kitchens Cemetery, 15Si64/ KHC number SI 536) were identified. Previously recorded archaeological sites 15Si31 and 15Si327, reported to be in or near the project, were not re-located. Of the identified resources, archaeological site 15Si61, a Middle or Late Archaic base camp, is recommended as being potentially eligible for inclusion in the NRHP. Site 15Si17 was previously listed as an “Inventory Site” and will retain its recommendation of not eligible for the NRHP. The remainder of the sites and isolated finds are recommended as being ineligible for inclusion in the NRHP. Based on these results, it is recommended that archaeological site 15Si61 and the Kitchens Cemetery should be avoided by any ground disturbing activities. If this is not possible, then additional investigations may be required. Figure 2.4 – Proposed Horus Kentucky Solar Project Site Layout includes the archaeological resource avoidance areas based on the results of the archaeological investigation. The remainder of the Project Area contains no significant resources and no additional archaeological investigations are warranted in these areas.
During the archaeological survey within Tennessee, no archaeological sites were identified. As a result of the investigations, two Precontact isolated finds (IF-1 and IF-2) and the Williams Family Cemetery were identified. All three resources are recommended as being ineligible for inclusion in the NRHP. Based on these results, no historic properties would be affected by the proposed undertaking and no further cultural resources work should be necessary. To comply with Tennessee State Law, however, the Williams Cemetery should be avoided by any ground disturbing activities within the existing ROW.
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3.6 Visual Resources This section describes an overview of the visual resources in and surrounding the Project Site and the potential impacts on these visual resources that would be associated with the No Action and Proposed Action Alternatives. It should be noted that no visual resources assessment was required along the Proposed Transmission Line Upgrades within Kentucky and Tennessee as any height change of the transmission lines are proposed to be no greater than 7–10 feet in height from the existing infrastructure.
Affected Environment Visual resources are visual characteristics of a place that includes both natural and man- made attributes. Such resources are important to people living in or traveling through an area and can be an essential component of historically and culturally significant settings. For this analysis, the scenery management system and associated analytical assessment procedures developed by the U.S. Forest Service are adapted for use within a natural and human-built environment and integrated with planning methods used by TVA. The general Project Site viewshed is evaluated based on its scenic attractiveness and scenic integrity. Scenic attractiveness is a measure of the scenic beauty of a landscape and is based on perceptions of the visual appeal of landforms, waterways, vegetation, and the human-built environment. Scenic attractiveness is assessed as either distinctive, typical/common, or indistinctive. As adapted for this analysis, scenic integrity measures the degree of visual unity of the natural and cultural character of the landscape. Scenic integrity is evaluated as either low, moderate, or high. This analysis also considers the existing character of the Project Site as an important factor in understanding the affected environment.
The Project Site is near the City of Franklin in Simpson County, Kentucky. The regional character is mostly rural, with agricultural fields, rolling hills, forested areas, and generally small towns. The Project Site is bounded to the north by Interstate-65 (I-65) and Old County Farm Road; to the east by Tyree Chapel Road and Hendricks Road; to the south by Tyree Chapel Road; and to the west by railroad tracks. The Project Site is surrounded by scattered residential and agricultural structures adjacent to the Project Site boundaries. The closest adjacent industrial development is the gas station/convenience store and truck stop located across the railroad tracks (along Nashville Road) approximately 500 feet west of the Project Site. The Tyree Chapel Church of Christ is located approximately 1,500 feet south of the Project Site. R&D Farms is located approximately 3,000 feet east of the Project Site. Based on a review of historical aerial photographs, the Project Site appears to have been primarily utilized as agricultural land since at least 1950. Adjoining properties appear to have been primarily utilized as agricultural and residential land since at least 1950. The Project Site is mostly agricultural land which is actively farmed with shrubby and forested areas present. The existing viewsheds constitute an almost completely agricultural setting, with few man- made attributes. Existing man-made attributes in the vicinity of the Project Site include residential and agricultural structures, farm equipment, railroads, highways, paved and dirt roads. In addition, as the Project Site is actively farmed, the uniformity of the cropland is a man-made visual disturbance. Due to the farming practices, the visual appearance of the Project Site varies throughout the year depending on the harvest cycle. As a consequence of the existing agricultural practices of the area, the Project Site already has an industrial aspect inserted into its aesthetics. The scenic attractiveness of the Project Site is rated as typical or common of a rural-agricultural and sparsely residential area. Scenic integrity is assessed as moderate to high due to the relative unity of the surrounding natural and cultural character.
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Figure 3.16 Viewshed Analysis of Proposed Horus Kentucky Solar Project Site
A viewshed analysis was conducted for the Project Site and surrounding sensitive receptors (such as residencies, churches, cemeteries) within a 2-mile radius. Figure 3.16 depicts the results of the viewshed analysis. Areas highlighted in red are areas where the Project Site
Draft Environmental Assessment 66 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences will not be visible, areas highlighted in green are areas where the Project Site will partially be visible. Figure 3.17 is a representative photograph of the visual aesthetics the Project Site.
Figure 3.17 Representative Photograph of the Visual Aesthetics of Horus Kentucky Solar Project Area
In order to comply with Simpson County ordinances, the following local set-back requirements are applicable to this Project Site: o 50 feet from public road right-of-way. o 100 feet from any abutting agricultural properties. o 250 feet from any residential-zoned properties, churches, cemeteries, nursing homes, and schools.
In addition, based on a Property Value Impact Study conducted by Kirkland Appraisals, LLC for the Project Site, the study concludes that the Project Site “would have no impact on the value of adjoining or abutting property and that the proposed use is in harmony with the area in which it is located”. The Property Value Impact Study further states that there have historically been more positive implications from a solar farm that have been expressed by various residents living next to solar farms to include: protection from future development of more intrusive uses, reduced dust, odor, and chemicals from former farming operations, protection from light pollution at night, minimal generation of noise or traffic from its operations, and lack of any potential hazardous waste byproduct or odor from its operations.
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Environmental Consequences
No Action Alternative Under the No Action Alternative, the Project Site would not be constructed; therefore, no Project-related impacts to visual resources would occur. Existing land use would remain as farmland and visual resources would remain as they are at the present time. However, indirect impacts to visual resources are possible as growth occurs within the City of Franklin and Simpson County. Over time, it is possible that the agricultural areas within and surrounding the Project Site could be developed if the residential population in the area grows significantly. Additionally, if the agricultural activities within the Project Site are discontinued, the existing land could revert to undeveloped property or developed for industrial purposes that may be more visually obtrusive than a solar power generating facility. Therefore, indirect impacts to visual resources are possible under the No Action Alternative as the current agricultural land may become residential or developed for other industrial purposes over the long-term.
Proposed Action Alternative Visual concerns are often associated with both large and small-scale solar facilities and its electrical infrastructure. The Project Site and its vicinity consists of relatively flat to gently sloping terrain, and the Proposed Action Alternative would convert what is largely now agricultural, rural-residential, and forested lands to an industrial use mostly consisting of low- profile PV arrays. The solar panels are all proposed at less than 15 feet in height, which means that the visual impact of the solar panels would be similar in height to a typical greenhouse structure (which are common within the Project Site’s agricultural region) and lower in height than a single-story residential dwelling.
The Simpson County setbacks would be followed, which would provide appropriate setbacks from the Project Site to abutting public road right-of-way, agricultural properties, and any residential-zoned properties, churches, cemeteries, nursing homes, and schools. Overall, while portions of the Project Site would be visible across open fields or otherwise clear areas, proposed visual barriers in the form of privacy fencing and vegetative screening would further mitigate the visual effects of the Project Site with its surrounding environment and aesthetics, and largely shield views from most Project Site vantage points to the solar facility.
Construction of the proposed Project Site would temporarily alter the visual character of the surround area. During construction, heavy machinery would be present, changing the visual aspects from Project Site vantage points. Within the 550-acre area to be developed, most of the area would be graded, changing the contour, color, and texture of the scenery attributes. The Project Site would appear as a mixture of neutral colors such as browns and grays due to earthmoving, road construction, and concrete activities. Water would be used to keep soil from aerosolizing; thus, dust clouds are not anticipated. Visual impacts from construction would be minimal at night since most construction is anticipated to occur during the day. Erosion control silt fence and sediment traps would be removed once construction is complete, and bare areas would be promptly vegetated. Indirect impacts to visual resources in the Project Site may occur due to increased traffic and movement of heavy machinery on the Project Site and along local roads. Overall, there would be minor direct and indirect impacts to visual resources during the construction phase of the Proposed Action. However, these impacts would be temporary (approximately 12-18 months).
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3.7 Noise This section provides an overview of the existing ambient sound environment in the Project Area, and the potential impacts to the ambient sound environment that would be associated with the No Action and Proposed Action Alternatives.
Affected Environment Noise pollution is sound that becomes unwanted with normal activities, disrupts normal activities, or diminishes one’s quality of life. Noise pollution can adversely affect a person’s health and lead to several stress related issues. Sound is usually represented on a logarithmic scale with a unit called the decibel (dB). Sound on the decibel scale is referred to as sound level. The threshold of human hearing is approximately zero dB, and the threshold of discomfort or pain is around 120 dB. Noise levels are computed over a 24-hour period and adjusted for nighttime annoyances to produce the day-night average sound level (DNL). DNL is the community noise metric recommended by the USEPA and has been adopted by most federal agencies. A DNL of 65 A-weighted decibels (dBA) is the level most commonly used for noise planning purposes and represents a compromise between community impact and the need for activities such as construction. The A-weighted sound level represents the approximate frequency response characteristic of the average young human ear. Areas exposed to a DNL above 65 dBA are generally not considered suitable for residential use. A DNL of 55 dBA was identified by USEPA as a level below which there is no adverse impact. For reference, approximate noise levels (measured in dBA) of common indoor and outdoor noises are provided in Table 3.12.
Table 3.12 List of Sound Pressure Levels of Common Indoor and Outdoor Noises
Common Indoor and Outdoor Noise Approximate Sound Pressure Levels (dBA)
Airplane Flyover at 1,000 Feet 120
Construction Saw at 3 Feet 110
Law nmower at 100 Feet 90
Vacuum at 10 Feet 80
Traffic 60
Serene Wilderness Areas ≤30
Noises occurring at night generally produce a greater annoyance than do noises of the same levels occurring during the day. People generally perceive intrusive noise at night as being 10 dBA louder than the same level of noise during the day. This perception is largely because background environmental sound levels at night in most areas are about 10 dBA lower than those during the day.
The Noise Control Act of 1972 established a federal policy to promote an environment free from noise that jeopardizes health and welfare. The USEPA guidelines, published in 1974, identified noise levels thresholds, measured in dBA that permit normal activities. The USEPA guidelines found that levels of ≤55 decibels outdoors and ≤45 decibels indoors were considered noise levels which permit daily activities such as conversation, sleeping, working, and recreation. In 1981, the USEPA determined that noise issues were best handled at the
Draft Environmental Assessment 69 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences state and local level. However, the USEPA still has the authority to investigate noise and its effect and effectiveness of existing regulations.
The amount of noise can be affected by distance and obstruction between the source and receiver. For example, as distance increases, the sound waves are dispersed. It is estimated that sound levels for a point source will decrease by 3 dBA for each doubling distance (AZ DOT, 2017).
Construction of the Project Site is expected to start in third quarter of 2021. It is expected that the weekly construction schedule would occur Monday through Friday between 7:00AM and 7:00PM; however, some construction activities could also occur on weekends if necessary. The Project Site would be constructed in several phases as it is expanded from one area to another. The beginning of construction in each phase would generate the most noise as this is when the heavy machinery would be operated.
In an open field, noise level dissipates at a rate of 6 dBAs every time the distance from the source doubles. If a source generates 100 dBA 3 feet from the source, then the source generates 94 dBA at 6 feet away and 88 dBA at 12 feet away and so on. Equation 1 can be used to calculate the difference in sound pressure level1.
Equation 1: dL=10*log(R2 / R1)2 Where; dL: change in sound pressure level (dBA) R1: distance from source to location 1 (ft, m) R2: distance from source to location 2 (ft, m)
In order to calculate the increase in the sound level from multiple sources the pressure from each sound source at the point of interest is summed and converted to decibels. Equation 2 is used to calculate the total raw pressure at a location from multiple sources using the raw pressure from each sound source2.
Equation 2: PT=(PA2+PB2+…+PF2)0.5 Where; PT: Total combined pressure at location 1 (µPa) PA: Pressure from source A at location 1 (µPa) PB: Pressure from source B at location 1 (µPa) PF: Pressure from the last source at location 1 (µPa)
The construction activities that would generate the most noise would take place during the construction phase are due to pile driving, potential rock drilling, vehicular traffic, and dozer grading work. The U.S. Department of Transportation Federal Highway Administration has measured noised impacts from construction activities and the expected noise associated with the potential equipment to be used during construction can be seen in Table 3.13.
1 Equation 1 from Estimating Sound Levels w ith the Inverse Square Law on HyperPhysics, an online reference book for physics by Georgia State University 2 Equation 2 from Adding Decibels on Engineering Toolbox, an online reference book for engineering equations.
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Table 3.13 Common Construction Equipment
Equipment Description Actual Measured Lmax @ 50 feet (dBA, slow) (Samples Averaged)
Dozer 82
Excavator 81
Front End Loader 79
Impact Pile Driver 101
Man Lift 75
Pickup Truck 75
Vibratory Pile Driver 101
Neighbors in close proximity to the construction activities likely would be able to notice the noises associated with the machinery required for construction. However, according to the study Farm Noise Emissions During Common Agricultural Activities done by Depczynski, Franklin, Challinor, Williams, and Fragar, the machinery required for construction has similar noise levels as farm equipment that are currently used in the area. Dozers, combines, tractors, irrigation pumps, semi-trucks, and chainsaws used by farmers can generate noise levels between 80 and 110 dBA. The specific farm related sources and noise levels as predicted in the study can be seen in Table 3.14.
Table 3.14 Common Farm Sound Levels
Machinery Average Noise Level at Noise Level Range at Operators Operators ear (dBA) e ar (dBA)
Air Compressor 86 72-95
All-Terrain Vehicle 86 84-87
Angle Grinder 98 96-100
Auger 93 89-96
Bulldozer 99 97-100
Chainsaw 106 104-107
Farm Truck 85 83-88
Fork Lift 84 81-88
Harvester 83 75-91
Irrigation Pump 100 96-104
Tractor 92 90-93
Any noise generated by the transport of equipment in and out of the Project Site would be comparable to the sound levels generated by the hauling of crops each season. Although construction noise levels would vary from day to day during construction depending on the
Draft Environmental Assessment 71 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences activity being performed, the overall generated noise levels during construction are expected to be similar to noise levels generated from typical farm activities. The sound levels indicated by the construction activities in Table 3.7 range from 75-101 dBA at a distance of 50 feet. Per Simpson County Zoning ordinances, the anticipated setbacks are 250 feet from any residential-zoned properties, churches, cemeteries, nursing homes, and schools. Intermittent ranges at the nearest property boundary are estimated to range from 61-87 dBA, when construction is within the closest range of the property boundary.
The noise impacts from constructing the Project Site on existing farmland would be temporary. The construction process would last approximately 12-18 months and would primarily occur during daylight hours during weekdays. Construction activities would not occur in a single location for the total duration but would occur in various locations around the project area. Most of the project area is large enough that noise sources would be sufficiently far from sensitive receptors to avoid impacts. The noise impacts from construction equipment is expected to be similar to the operation of typical farm equipment; as such, the construction of the solar project is not anticipated to have a significant impact on surrounding community noise levels or sensitive receptors.
The operation of the Project Site would primarily generate noise from two main sources; invertors and transformers. The emissions are generally not audible at the property line when the proper setback distances are used from sensitive receptors. The Project Site would have inverters and transformers. Inverters are used on solar farms to turn the DC power generated by the solar panels into AC. Transformers are used on solar farms to increase the alternating voltages generated by the invertors and help facilitate the transmission, distribution, and utilization of AC for electrical energy. The Project Site would also use a motorized tracking system in order to keep the panels facing the sun and optimize output during different times of the day and year. The motors used to move the panels are small and are inaudible when in close proximity. The other source of noise would be from the substation transformer.
The Project Site is anticipated to use 22 inverter/transformer located throughout the property. Each individual noise source adds to the total measurable noise level; however, as stated above, the doubling of the distance from the previous reference measuring point decreases the number of decibels registered. The inverters are rated by the manufacturer at <79 dBA at 3 feet and would be scattered throughout the solar array. Each inverter would produce 31 dBA using the 250-foot setback from any residential-zoned properties, churches, cemeteries, nursing homes, and schools. Rural ambient background levels during the day are generally 40-45 dBA depending on the proximity to existing noise sources. The inverters would not be audible over the background sound levels at sensitive receptors assuming the 250-foot setback. Similar propagation would also reduce the substation levels below ambient conditions at the 250-foot setback.
Anticipated operational maintenance operations would include grass mowing and general solar panel maintenance. The upkeep and small fixes are not anticipated to generate any loud or distinguishable noise from off the Project Site. The Project would generally have the grass mowed three to four times a year, this would be done during the day. Riding lawn mowers typically operate around 90 dBA. Due to the large area being mowed, the distance from the mower to anywhere off-site would create an environment where the sound generated from mowing would largely go unnoticed. Secondly, the mowing of grass already takes place at each resident’s household and is generally accepted as a common noise. Finally, the last potential for increasing the ambient noise level of the Project Site would be an increase in traffic into and around the site. The estimated number of vehicles needed to
Draft Environmental Assessment 72 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences service the solar farm amounts to 10 vehicles on days when the panels are serviced and the grass is mowed, which is not expected to have any significant noise impacts.
Environmental Consequences
No Action Alternative Under the No Action Alternative, the Project Site would not be constructed; therefore, no Project-related impacts to noise would occur. Existing land use would remain as farmland and the ambient sound environment would remain as they are at the present time. However, indirect impacts to noise are possible as growth occurs within the City of Franklin and Simpson County. Over time, it is possible that the agricultural areas within and surrounding the Project Site could be developed if the residential population in the area grows significantly. Additionally, if the agricultural activities within the Project Site are discontinued, the existing land could be developed for industrial purposes that may generate more noise than a solar power generating facility. Therefore, indirect impacts to ambient sound environment are possible under the No Action Alternative as the current agricultural land may be developed for other industrial purposes over the long-term.
Proposed Action Alternative Under the Proposed Action Alterative, direct and indirect noise impacts would primarily occur during the construction phase as noise levels would temporarily increase during construction of the Project Site. Based on the above, noise-generating sources (inverters and transformers within the Project Site) were found to not result in sound levels of significance beyond the Project Site boundaries and are not anticipated to have a significant impact on surrounding community noise levels or sensitive receptors. In addition, Simpson County setbacks would be followed, which would provide appropriate setbacks from the Project Site to abutting sensitive receptors like public road right-of-way, agricultural properties, and any residential- zoned properties, churches, cemeteries, nursing homes, and schools.
Typical farming equipment like dozers, combines, tractors, irrigation pumps, semi-trucks, and chainsaws used by farmers can generate noise levels between 80 and 110 dBA. The current agricultural operations surrounding the Project Site likely already produces ambient sounds that would help make effects from the Project more minimal. Additionally, construction would primarily occur during daylight hours, between sunrise and sunset; therefore, the Project Site would not affect ambient noise levels at night during most of the construction period. Most of the proposed equipment would not be operating on site for the entire construction period but would be phased in and out according to the progress of the Project.
Following completion of construction activities, the ambient sound environment on and surrounding the Project Site would be expected to return to existing levels or below, by eliminating some seasonal use of agricultural equipment. The moving parts of the PV arrays would be electric-powered and produce little noise. The periodic mowing of the Project Site to manage the height of vegetation surrounding the solar panels would produce sound levels comparable to those of commercial and agricultural operations in the Project Site; however, Project-related mowing would occur at less frequent quarterly intervals than typical agricultural operations. Consequently, the Proposed Action would have minimal effects on noise levels as a result of normal continuous operation.
Overall, implementation of the Proposed Action would result in minor, temporary adverse impacts to the ambient noise environment in the Project Area during construction, and minimal to negligible impacts during operation and maintenance of the solar facility.
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Similarly, minor, temporary adverse impacts to the ambient noise environment would be anticipated within the Project Transmission Line Upgrades. These activities would be temporary and negligible since it would occur along the existing ROW that is regularly maintained.
3.8 Transportation This section describes an overview of existing transportation resources at and near the Project Area and the potential impacts on transportation resources that would be associated with the No Action and Proposed Action Alternatives. Components of transportation resources that are analyzed include roads, traffic, railroads, and airport.
Affected Environment The Project Site is bounded to the north by I-65 and Old County Farm Road; to the east by Tyree Chapel Road and Hendricks Road; to the south by Tyree Chapel Road; and to the west by railroad tracks. Available data collected from the Kentucky Transportation Cabinet (KYTC) Traffic Counts portal and other entities were used to assess the existing roadway networks around the subject location and impacts that may occur due to development of the site. Utilizing the KYTC website, existing traffic, projected traffic, heavy vehicle volumes, distances and specific routes to and from the National Truck Network were assessed. Two annual average daily traffic (AADT) stations were located nearby the Project Site along I- 65. Data for the several local roads (such as Tyree Chapel Road and Hendricks Road) were not available through KYTC database. I-65 Station 107P91 (Route #107-I-0065-000) located directly adjacent to the north of the Project Site and I-65 Station 107256 (Route #107-US-0031W-000) is located approximately 1,300 feet west of the Project Site. The historical and current AADT for the two stations are listed in Table 3.15. Table 3.15 AADT Counts from Two Traffic Stations
Year 107P91 107256 2020 43,007 - 2019 49,388 - 2018 48,187 10,841 2017 48,143 - 2016 46,778 - 2015 45,234 10,341 2014 41,040 - 2013 43,773 - 2012 - 10,037 2011 - - 2010 - -
Several local roads extend through and, thus, provide access to the Project Site. There are also several unnamed, gravel local roads that extend through the Project Site as well. The closest rail line operated by CSX bounds the Project Site directly to the west. The closest general aviation airport is the Portland Municipal Airport located approximately 5.5 miles southeast of the Project Site.
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Environmental Consequences
No Action Alternative Under the No Action Alternative, the Project Site would not be constructed; therefore, no Project-related impacts to transportation resources would occur. Existing land use would remain as farmland and existing transportation network and traffic conditions would remain as they are at the present time.
Proposed Action Alternative Under the Proposed Action, new construction and increase in construction related traffic is anticipated. The construction crew, estimated at 100 people, would commute to the Project Site between sunrise and sunset. A majority of these workers would likely come from the local area or region. Other workers would come from outside the region, and many would likely stay in local hotels in the vicinity. Traffic flow around the Project Site would be heaviest at the beginning of the work day, at lunch, and at the end of the work day. The construction phase would last at least 12 to 18 months and would only take place during working hours, leading to a minimal increase in traffic for those months. This traffic would include cars, trucks, equipment taxiing, and larger construction vehicles. The primary phase of construction would include any necessary clearing and grading. The secondary phase of construction would include the construction.
Construction activities would temporarily increase traffic through the area and along the three main roads with one primary entrance and exit to the site. Construction traffic impacts would be temporary and minor, and not result in the need for special traffic routes or road enhancements to accommodate construction equipment. However, should substantial traffic congestion occur, Horus Renewables would implement staggered work shifts during daylight hours to assist traffic flow near Project Site access locations. Implementation of such mitigation measures would minimize potential adverse impacts to traffic and transportation to negligible levels. The construction and operation of the Project Site would have no effect on operation of the airports in the region. The operation of the Project would not affect commercial air passenger traffic or freight traffic in the region and would not adversely affect any aerial crop dusters operating in the vicinity of the Project Site. Overall, direct impacts to transportation resources associated with implementation of the Proposed Action would be anticipated to be minor to moderate and minimized or mitigated. The Proposed Action would not result in any indirect impacts to transportation.
Similarly, minor, temporary impacts to transportation resources would be anticipated within the Project Transmission Line Upgrades. These activities would be temporary and negligible since it would occur along the existing ROW that is regularly maintained and experiences operations and maintenance traffic.
3.9 Air Quality and Climate Change This section describes existing air quality and greenhouse gas (GHG) emissions in the Project Area and the potential impacts on air quality and GHG emissions that would be associated with the No Action and Proposed Action Alternatives.
Affected Environment
Regional Air Quality Ambient air quality is determined by the type and concentration of pollutants emitted into the atmosphere, the size and topography of the air shed in question, and the prevailing
Draft Environmental Assessment 75 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences meteorological conditions in that air shed. Through its passage of the Clean Air Act of 1970 (CAA) and its amendments, Congress mandated the protection and enhancement of our nation’s air quality. USEPA established the National Ambient Air Quality Standards (NAAQS) for the following criteria pollutants to protect the public health and welfare: sulfur dioxide (SO2), ozone, nitrogen dioxide, particulate matter whose particles are less than or equal to 10 micrometers (PM10), particulate matter whose particles are less than or equal to 2.5 micrometers (PM2.5), carbon monoxide (CO), and lead. The primary NAAQS were promulgated to protect public health, and the secondary NAAQS were promulgated to protect public welfare (e.g., visibility, crops, forests, soils, and materials) from any known or anticipated adverse effects of air pollutants. Areas in compliance with the NAAQS are designated “attainment” areas. Areas not in compliance with the NAAQS are designated as “nonattainment” areas. New sources being located in or near nonattainment areas may be subject to more stringent air permitting requirements. Nonattainment areas are usually defined by county. National standards, other than annual standards, may not be exceeded more than once per year (except where noted). Areas that cannot be classified on the basis of available information for a particular pollutant are designated as “unclassifiable” and are treated as attainment areas unless proven otherwise. Finally, areas that were formerly designated as nonattainment for a pollutant and later come into attainment are then categorized as “maintenance” for that pollutant for the next 20 years, assuming they continue to meet the NAAQS for that pollutant. If an area remains in attainment for the 20-year maintenance period, the status reverts back to normal attainment.
The primary NAAQS were promulgated to protect public health, and the secondary NAAQS were promulgated to protect public welfare (e.g., visibility, crops, forests, soils, and materials) from any known or anticipated adverse effects of air pollutants. Primary and secondary standards are listed in Table 3.16.
Table 3.16 National Ambient Air Quality Standards Criteria Pollutant Average Primary Standard Secondary Standard CO 8 hours 9 ppm none CO 1 hour 35 ppm none SO2 1 hour 75 ppb none SO2 3 hours none 0.5 ppm NO2 1 hour 100 ppb none NO2 1 year 53 ppb Same as primary Pb Rolling 3-month average 0.15 μg/m3 Same as primary O3 8 hours 0.070 ppm Same as primary 3 PM10 24 hours 150 μg/m Same as primary 3 PM2.5 24 hours 35 μg/m Same as primary 3 3 PM2.5 1 year 12.0 μg/m 15 μg/m
Areas in compliance with the NAAQS are designated “attainment” areas. For areas USEPA designates as nonattainment, there are several categories from marginal to severe that USEPA could assign depending on the severity of the nonattainment. A nonattainment designation requires that a region submit a State Implementation Plan (SIP) that addresses how the NAAQS would be met in a future year. USEPA later determines whether the region has met the SIP goals, and if so, USEPA changes the designation from nonattainment area to maintenance area. The CAA General Conformity Rule requires that federal actions taking place in nonattainment areas conform to the region’s SIP for reducing airborne concentrations of the nonattainment pollutant(s).
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The State of Kentucky adopted the NAAQS as the state ambient air standards and administers the delegable provisions of the CAA. The Kentucky rules regarding Attainment and Maintenance of the National Ambient Air Quality Standards, set in place by the Department for Environmental Protection (DEP) of the Energy and Environment Cabinet (EEC), are found in Kentucky Administrative Regulations Title 401 (401 KAR), Chapters 51 and 53. Chapters 51 and 53 regulations include emission standards and control requirements on both a pollutant-specific basis and process/equipment/industry specific basis. Division 3 also sets forth the permitting requirements for air emission sources.
The Project Site is located in Simpson County, Kentucky. Simpson County is in attainment with applicable NAAQS and meets applicable federal and state air quality standards. The most recent available measurements of ambient air concentrations closest to the Project area shown in Table 3.17 are consistent with the above designation. Therefore, the Project Site is located in an area with good air quality.
Simpson County has not been included on the NAAQS non-attainment list for Kentucky, which includes all Kentucky counties in non-attainment since 1992; therefore, Simpson County, Kentucky has been in attainment since at least 1992. Table 3.17 lists the pollutant concentration values from the air monitoring sites closest to the Project area in Simpson County. These concentrations, which represent air quality near the Project area, are in the form used to determine attainment with NAAQS. The only NAAQS pollutant reported in Simpson County is Ozone. The other NAAQS do not require monitoring due to EPA’s set minimum requirements. The monitored pollutant concentrations are well below the standards.
Table 3.17 Air Quality in Simpson County, Kentucky Pollutant Metric Amount CO Second maximum non-overlapping 8-hour concentration ND* Pb Maximum rolling 3-month average ND* Arithmetic mean concentration ND* NO2 98th percentile daily maximum 1-hour concentration ND* O3 Fourth daily maximum 8-hour concentration 0.059 ppm** PM10 Second maximum 24-hour concentration ND* Weighted annual mean concentration ND* PM2.5 98th percentile 24-hour concentration ND* SO2 99th percentile daily maximum 1-hour concentration ND* * No Data ** Applicable NAAQS is 0.070 ppm
Since Simpson County, where the Project Site is located, is in attainment for all criteria pollutants, the CAA General Conformity rules would not apply to the implementation of the Proposed Action and a general conformity applicability analysis is not required. Average emissions in Simpson County of pollutants for which NAAQS have been established are presented in Table 3.18.
Table 3.18 Average Emissions of NAAQS Pollutants in Simpson County, Kentucky for 2017 Pollutant Emissions (tons per year) CO 4,070.78 Pb 0.19 Nitrogen Oxides (NOx) 1,250.99 PM2.5 382.46
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PM10 1,475.40 SO2 5.96 Volatile Organic Compounds (VOCs) 2,926.02
Regional Climate Weather conditions determine the potential for the atmosphere to disperse emissions of air pollutants. Kentucky’s climate is characterized by hot, wet, humid summers with average temperatures around 95 degrees Fahrenheit (°F) and cold winters with night temperatures below 23°F. The average rainfall in Kentucky is 45” per year. Snowfall is typically 15-20” in Kentucky, mainly in the north and east. The southern region, to include Simpson County, receives an average of 50” of annual precipitation. On an annual basis, sunshine lasts approximately 2,700 hours. In the southern regions, there are roughly 60 freezing days.
GHGs GHGs are compounds found naturally within the earth’s atmosphere. These compounds trap and convert sunlight into infrared heat. In this way, GHGs act as insulation in the stratosphere and contribute to the maintenance of global temperatures. As the levels of GHGs increase at ground level, the result is an increase in temperature on earth, commonly known as global warming. The climate change associated with global warming is predicted to produce negative economic and social consequences across the globe through changes in weather (e.g., more intense hurricanes, greater risk of forest fires, flooding).
The most common GHG emitted from natural processes and human activities include carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O). The primary GHG emitted by human activities in the US is CO2, representing approximately 81 percent of total U.S. emissions in 2018. The largest source of CO2 and of overall GHG emissions is fossil fuel combustion. CH4 emissions, which have declined from 1990 levels, result primarily from enteric fermentation (digestion) associated with domestic livestock, decomposition of wastes in landfills, and natural gas systems. Agricultural soil management and mobile source fuel combustion are the major sources of N2O emissions in the US.
TVA has ensured that climate change adaptation is integrated in agency-wide and regional planning efforts with other federal, state, and local agencies. In these efforts, TVA has established the Climate Change Adaption Action plan, which is integrated in major planning processes. This Adaption Action Plan allows TVA to identify and assess potential consequences and ability to mitigate climate change and develop adaptation planning action. In 2013, TVA initiated the Climate Change Sentinel Monitoring (CCSM) program, which assesses potential biological, ecological, and hydrological responses of aquatic ecosystems related to climate change. Additionally, TVA partakes in several partnerships aimed at improving energy infrastructure to climate change impacts.
Environmental Consequences
No Action Alternative Under the No Action Alternative, the Project Site would not be constructed; therefore, no Project-related air pollutants or GHGs would be generated by equipment or vehicles from construction or operation of the Project. Existing land use would remain as farmland as it is at present, with little effect on climate and air quality. The main source of emissions in the Project Site would continue to be from mobile sources such as automobiles and agricultural equipment.
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Proposed Action Alternative Under the Proposed Action, minor direct impacts to air quality would be anticipated as a result of construction and operation of the Project Site. Temporary impacts to GHG emissions expected during construction would be negligible.
Emissions on a construction site generally result from the engine exhaust of heavy construction equipment (e.g., bulldozers, dump trucks, pile drivers, etc.) powered by internal combustion engines, other motor vehicle exhaust, and fugitive dust. Emissions associated with the combustion of gas and diesel fuels by internal combustion engines would generate local emissions of particulate matter, NOx, CO, VOCs, and SO2 during the construction period. Air quality impacts from construction activities would depend on both man-made factors (intensity of activity, control measures, etc.) and natural factors such as wind speed and direction, soil moisture, and other factors. However, even under unusually adverse conditions, these emissions would have, at most, a minor transient impact on off-site air quality, which would remain well below the applicable ambient air quality standard.
Fugitive dust emissions from earth-moving activities, the use of unpaved haul-roads and soil disturbance have the potential to lead to substantial amounts of airborne particulates (dust) that can negatively impact air quality. Approximately 500 acres of the Project Site could be subject to grading and/or ground-disturbing activities which have the potential to emit fugitive dust. In addition, grading activities result in soil disturbance that can make soils vulnerable to wind erosion. Properly implemented control and suppression measures, as well as BMPs (such as covered loads and wet suppression), greatly minimize fugitive dust emissions. In addition, standard erosion control measures, such as redistribution of removed topsoil and reseeding, would minimize the potential for wind erosion.
Overall, with adherence to regulations and BMPs, air emissions associated with the construction of the Project Site are expected to be minor. Emissions from construction would have, at most, a minor transient impact on air quality, which would remain well below the applicable ambient air quality standards. Therefore, the potential impacts to air quality associated with construction under the Proposed Action would be minor and temporary (lasting for a period of 12 to 18 months).
The operation of the Project Site is not anticipated to have any adverse impacts to air quality or GHG emissions, as only minor maintenance would be expected to occur, which would not constitute a major source of air pollutants. Conversely, overall pollutant emissions from the TVA power system would decrease during operations as the emissions-free power generated by the solar facility would offset power that would otherwise be generated, at least in part, by the combustion of fossil fuels. The solar facility would be part of the cleaner, lower-emitting generating portfolio described in the TVA 2019 IRP and would contribute to the approximately 44 percent reduction in CO2 emissions. While the reductions in air pollutants and CO2 emissions attributable to the solar facility would be relatively minor, they would be a component of TVA’s projected significant overall reductions, the associated beneficial impacts to air quality, and the reduced impacts from climate change.
Similarly, minor, temporary generation of air pollutants or GHGs would be anticipated within the Project Transmission Line Upgrades. These activities would be temporary and negligible since it would occur along the existing ROW that is regularly maintained and experiences operations and maintenance traffic. Adherence to BMPs would also be followed for upgrades along the existing ROW to further minimize impacts to air quality.
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Lastly, agricultural practices, which currently raise dust and combustion byproducts, would be discontinued at the Project Site. Therefore, operations could ultimately result in a minor beneficial impact to local air quality.
3.10 Public Health and Safety This section describes an overview of existing public health and safety within the Project Area and the potential impacts to public health and safety associated with the No Action and Proposed Action Alternatives. Analyzed issues include emergency response and preparedness and occupational, or worker safety in compliance with OSHA standards.
Affected Environment The discussion of safety includes consideration for any activities, occurrences, or operations that have the potential to affect the safety, well-being, or health of members of the public. A safe environment is one in which there is no, or optimally reduced, potential for death, serious bodily injury or illness, or property damage. The primary goal is to identify and prevent potential accidents or impacts on the general public. Public health and safety during construction, demolition, and renovation activities is generally associated with construction traffic, as well as the safety of personnel within or adjacent to the construction zones. Operational safety may refer to the actual use of the facility or built-out proposed project, or training or testing activities and potential risks to inhabitants or users of adjacent or nearby land and water parcels. Safety measures are often implemented through designated safety zones, warning areas, or other types of designations. Environmental health and safety risks to children are defined as those that are attributable to products or substances a child is likely to come into contact with or ingest, such as air, food, water, soil, and products that children use or to which they are exposed. Executive Order 13045, Protection of Children from Environmental Health Risks and Safety Risks requires federal agencies to “make it a high priority to identify and assess environmental health and safety risks that may disproportionately affect children and shall ensure that its policies, programs, activities, and standards address disproportionate risks to children that result from environmental health risks or safety risks.”
The Project Site is currently private property, and is surrounded by agricultural, rural- residential, and undeveloped land uses. Public emergency services in the area include urgent care clinics, hospitals, law enforcement services, and fire protection services. The Fast Pace Health Urgent Care located on Nashville Road, Franklin, approximately 3 miles northwest of the Project Site (10 minutes), is the closest urgent care center to the Project Site. The Medical Center at Franklin on Brookhaven Road, also in Franklin, approximately 3.5 miles northwest of the Project Site (12 minutes), is the closest hospital to the Project Site. Law enforcement services in Simpson County is provided by the Simpson County Sheriff’s Department in Franklin, approximately 5 miles northwest of the Project Site (15 minutes). Fire protection services are provided by Simpson County Fire Department in the Franklin, approximately 4 miles northwest of the Project Site (15 minutes). The Kentucky Energy and Environment Cabinet – Department of Environmental Protection has the responsibility and authority to coordinate with state and local agencies in the event of a release of hazardous materials.
Environmental Consequences
No Action Alternative Under the No Action Alternative, the Project Site would not be constructed; therefore, no Project-related impacts on public health and safety would result. Existing land use would be
Draft Environmental Assessment 80 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences expected to remain agricultural and existing public health and safety issues would be expected to remain as they are at present.
Proposed Action Alternative During construction, workers on the Project Site would have an increased safety risk. However, because construction work has known hazards, the standard practice is for contractors to establish and maintain health and safety plans in compliance with OSHA regulations. Health and safety plans emphasize BMPs for site safety management to minimize potential risks to workers. Examples of BMPs include employee safety orientations; establishment of work procedures and programs for site activities; use of equipment guards, emergency shutdown procedures, lockout procedures, site housekeeping, and personal protective equipment; regular safety inspections; and plans and procedures to identify and resolve hazards. Potential public health and safety hazards could result from increased traffic on roadways due to construction of the Project. Residential and other human use areas along roadways used by construction traffic to access the Project Site would experience increased commercial and industrial traffic. Awareness of these residences and establishment of traffic procedures to minimize potential safety concerns would be addressed in the health and safety plans followed by construction contractor(s).
Fuel for vehicles would be kept on site in storage tanks during construction of Project Site. An SPCC plan would be implemented to minimize the potential of a spill and to instruct on- site workers on how to contain and clean up any potential spills. The perimeter of the Project Site would be securely fenced during construction and for the duration of operation, and access gates would normally remain locked. General public health and safety would not be at risk in the event of an accidental spill on site. Emergency response for the Project Site would be provided by the local, regional, and state law enforcement, fire, and emergency responders, as described in the prior section. No public health or safety hazards would be anticipated as a result of operations. Overall, impacts to public health and safety in association with implementation of the Proposed Action would be considered temporary and minor.
Similarly, increased safety risk during construction would be anticipated within the Project Transmission Line Upgrades. These activities would be temporary and negligible since it would occur along the existing ROW that is regularly maintained and experiences operations and maintenance traffic. TVA’s Safety Standard Programs and Processes would be strictly adhered to during the proposed actions to decrease potential for safety risk.
3.11 Solid Waste and Hazardous Waste This section describes an overview of existing waste management within the Project Area and the potential impacts of managing wastes generated by the No Action and Proposed Action Alternatives. Components of waste management that are analyzed include solid and hazardous waste and materials.
Affected Environment “Hazardous materials” and “hazardous waste” are substances that, because of their quantity, concentration, or characteristics (physical, chemical, or infectious), may present a significant danger to public health and/or the environment if released. These substances are defined by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA; 42 U.S.C. §§ 9601 et seq.) and the Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery Act ([RCRA]; 42 U.S.C. §§ 6901 et seq.). Regulated hazardous wastes under RCRA include any solid, liquid, contained gaseous, or semisolid waste or
Draft Environmental Assessment 81 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences combination of wastes that exhibit one or more of the hazardous characteristics of ignitability, corrosivity, toxicity, or reactivity, or is listed as a hazardous waste under 40 CFR part 261. Storage and use of hazardous materials and wastes are regulated by local, state, and federal guidance including the Emergency Planning and Community Right-to-Know Act (42 U.S.C. §§ 116 et seq.) and RCRA.
Solid waste consists of a broad range of materials that include refuse, sanitary wastes, contaminated material, scrap metals, nonhazardous wastewater treatment sludge, nonhazardous air pollution control wastes, various nonhazardous industrial waste, and other materials (solid, liquid, or contained gaseous substances). Solid wastes are generally managed through recycling and local landfills. Collection and disposal of solid waste within the City of Franklin is conducted by Scott Waste Services, as they are the exclusive residential garbage collection service for the locality. Scott Waste Services also specializes in commercial waste collection for Simpson County.
A Phase I Environmental Site Assessment for the Project Site was performed consistent with the procedures included in ASTM E1527-13, Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process (provided in Appendix E). The purpose of the ESA is to assist in developing information to identify Recognized Environmental Conditions (RECs) in connection with the Project Site through user-provided information, a regulatory database review, historical and physical records review, interviews, including local government inquiries, as applicable, and a visual noninvasive reconnaissance of the Project Site and adjoining properties. RECs were not identified in the ESA. Therefore, additional investigation was not warranted. While neither the Project Site nor adjoining properties were identified in the regulatory database information reviewed, information provided by the Kentucky Department for Environmental Protection (KDEP) in response to a Freedom of Information Act (FOIA) request indicated the presence of apparently four (4) on- site oil wells in 1985 in the northern portion of the northwestern portion of the Project Site.
Current status of the reported wells was not identified in regulatory file information received from KDEP. The owner of the parcel in question was subsequently interviewed, and stated that the well information was accurate, but that the wells were subsequently abandoned and are no longer present/intact (at least to the extent of typical agricultural activity/plowing operations). Based on the owner interview, neither the KDEP file information related to historical oil wells on the site, nor the historical presence of the wells on the site, is considered a REC. With respect to the historical presence of oil wells in the northern portion of the Project Site, or the potential remaining presence of subsurface well components below agricultural plow depths, based on typical solar equipment/infrastructure installation methods, impacts to the Project Site in relation to the historical oil wells is not anticipated.
Environmental Consequences
No Action Alternative Under the No Action Alternative, the Project Site would not be constructed; therefore, no Project-related impacts on waste management would result.
Proposed Action Alternative Under the Proposed Action, storage and use of liquid materials in the form of petroleum- based oils and fuels, and generation of liquid and solid wastes in the form of used oil, construction debris, packing materials, and general construction waste would occur. During construction of the Project Site, materials would be stored on site in storage tanks, vessels,
Draft Environmental Assessment 82 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences or other appropriate containers specifically designed for the characteristics of these materials. The storage facilities would include secondary containment in case of tank or vessel failure. Construction- and decommissioning-related materials stored on-site would primarily be liquids such as used oil, diesel fuel, gasoline, hydraulic fluid, and other lubricants associated with construction equipment. Safety Data Sheets for all applicable materials present on site would be made readily available to on-site personnel. Fueling of some construction vehicles would occur within the construction areas. Other mobile equipment would return to the on-site laydown areas for refueling. Special procedures would be identified to minimize the potential for fuel spills, and spill control kits would be carried on all refueling vehicles for activities such as refueling, vehicle or equipment maintenance procedures, waste removal, and tank clean-out. A fuel truck may be stored on site for approximately 12-18 months during construction of the Project. The total volume of the on- site tanks is not anticipated to exceed 1,320 gallons, the threshold above which an SPCC plan may be required (40 CFR part 112). The Project Site would fall under USEPA’s SPCC requirements of “oil-filled operational equipment” and a Tier I Qualified Facility; therefore, no double-walled protection would be required, and the SPCC plan would not have to be certified by a Professional Engineer (USEPA 2006, 2011). The SPCC plan would be prepared prior to construction to prevent oil discharges during facility operations. During operations, bulk chemicals would be stored in storage tanks; other chemicals would be stored in returnable delivery containers. Chemical storage areas would be designed to contain leaks and spills. The transport, storage, handling, and use of chemicals would be conducted in accordance with applicable federal, state, and local laws, ordinances, regulations, and standards. While the various transformers would contain oil, there would be no separate oil or hydraulic fluid stored on-site related to transformers. The quantities of these materials stored on-site would be evaluated to identify the required usage and to maintain sufficient inventories to meet use rates without stockpiling excess chemicals.
Horus Renewables would develop and implement a variety of plans and programs to ensure safe handling, storage, and use of hazardous materials (e.g., Hazardous Material Business Plan). Facility personnel would be supplied with appropriate personal protective equipment (PPE) and would be properly trained in the use of PPE as well as the handling, use, and cleanup of hazardous materials used at the facility and the procedures to be followed in the event of a leak or spill. Adequate supplies of appropriate cleanup materials would be stored on site.
Similarly, increased waste generation during construction would be anticipated within the Project Transmission Line Upgrades. Construction waste and debris would be placed in roll- off dumpsters and disposed of at a permitted off-site construction and demolition landfill. Management of construction waste generated would in accordance with applicable federal and state laws and regulations and procedures outlined in TVA’s current Environmental Procedures and applicable BMPs. Therefore, minor impacts from generation of solid waste and no impact from hazardous waste generation are anticipated. BMPs would be used to prevent the introduction of soil or any other pollutants into nearby waterbodies.
3.12 Socioeconomics and Environmental Justice This section describes an overview of existing socioeconomic conditions within the Project Site and the potential impacts to socioeconomic conditions and environmental justice that would be associated with the No Action and Proposed Action Alternatives. Components of socioeconomic resources that are presented include population, employment, and income. It should be noted that no socioeconomics and environmental justice assessment was required along the Proposed Transmission Line Upgrades within Kentucky and Tennessee. Given the
Draft Environmental Assessment 83 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences scope of the Proposed Transmission Line Upgrades, there would be no discernable impact to demographic and community characteristics as the surrounding workforce and regional economy are not expected to change as a result of the upgrades along the existing ROW.
3.12.1 Socioeconomics
Affected Environment The population of Simpson County, as reported in the 2019 U.S. Census Population, is 18,572, with a median age of 39.5, and a median household income of $48,632. In 2018, households in Simpson County had a median annual income of $48,311, which is less than the median annual income of $61,937 across the entire U.S. This is in comparison to a median income of $44,989 in 2017, which represents a 7.38% annual growth. Simpson County had a total employment in 2019 of about 8,526 jobs, with the current unemployment rate at 4.4%. Per the Data USA information on Simpson County, the largest industries in the county are Manufacturing (2,270 people), Retail Trade (1,025 people), and Health Care & Social Assistance (893 people), and the highest paying industries are Professional, Scientific, & Technical Services ($53,036), Utilities ($50,700), and Real Estate & Rental & Leasing ($46,806). The table below illustrates the breakdown of primary jobs held by residents of Simpson County.
Figure 3.18 Employment by Occupations in Simpson County
In addition, the most common employment sectors for those who live in Simpson County are Manufacturing (2,270 people), Retail Trade (1,025 people), and Health Care & Social Assistance (893 people). The chart below illustrates the breakdown of employment by industries for residents of Simpson County.
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Figure 3.19 Employment by Industries in Simpson County
The per capita income for Simpson County in 2019 was $24,458, which is less than the per capita income for the Commonwealth of Kentucky of $28,178 and also behind the national average of $34,103.
Table 3.19 Per Capita Personal Income Data
Project Area Low-Income Populations Simpson County $24,458
Commonwealth of Kentucky $28,178
U.S. $34,103
Environmental Consequences
No Action Alternative Under the No Action Alternative, the Project Site would not be constructed; therefore, no Project-related impacts on socioeconomics would result. Existing land use would be expected to remain farmland and existing socioeconomic conditions would be expected to remain as they are at present. However, no short-term beneficial socioeconomic impacts from the Project Site construction and operations would occur.
Proposed Action Alternative Under the Proposed Action Alternative, the Project Site would be constructed and operated. Horus Renewables anticipates capital construction costs of $80 million for the Project Site. The Project Site is estimated to provide approximately 100 full-time jobs during construction for over a 12 to 18-month period. Short-term beneficial economic impacts would result from construction activities associated with the Project, including the purchase of materials, equipment, and services and a temporary increase in employment and income. This increase would be local or regional, depending on where the goods, services, and workers were obtained. It is likely some construction materials and services would be purchased locally in Simpson County and/or in adjacent counties. Most of the other components of the solar and transmission facilities would be acquired from outside the local area. Also, many of the construction workforce would likely be sought locally or within the region. The direct impact
Draft Environmental Assessment 85 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences to the economy associated with construction of the Project Site would be short-term and beneficial.
The majority of the indirect employment and income impacts would be from expenditure of the wages earned by the workforce involved in construction activities, as well as the local workforce used to provide materials and services. Construction of the Project Site could have minor beneficial indirect impacts to population and short-term employment and income levels in Simpson County.
In addition, several local technicians and maintenances employees would be hired for the Project Site’s regular operation and maintenance for the life of the Project, which is expected for a minimum of 15 years per the PPA. Following the expiration of the 15-year PPA with TVA, Horus Renewables would reassess the Project operation and determine whether to enter into a new PPA or other arrangement which could extend the life of the project. The Project would impact the local economy through the construction of the facility and also provide ongoing beneficial impacts from local and state taxes over the life of the Project. Grounds maintenance and some other operation and maintenance activities may be conducted by local contractors. Therefore, operations of the Project would have a small positive impact on employment and population in Simpson County.
Overall, socioeconomic impacts for the operation of the Project Site would be positive and long-term, while small relative to the total economy of the region. The local tax base would increase from construction of the solar facility and would be most beneficial to Simpson County and the vicinity. Additionally, the local governments would not have to provide any of the traditional government services typically associated with a large capital investment, such as water, sewer, or schools.
3.12.1 Socioeconomics
Affected Environment Executive Order 12898 (59 CFR 7629) directs federal agencies to identify and address, as appropriate, potential disproportionately high and adverse human health or environmental effects of their programs, policies, and activities on minority and low-income populations. In identifying minority and low-income populations, the following CEQ definitions or minority individuals, minority populations, and low-income populations were used:
o Minority Individuals: Individuals who identify themselves as members of the following population groups: American Indian or Alaskan Native, Asian, Native Hawaiian or Other Pacific Islander, Black, Hispanic, or two or more races. o Minority Populations: Minority populations are identified where: 1) the minority population of an affected area exceeds 50 percent or 2) the minority population percentage of the affected area is meaningfully greater than the minority population percentage in the general population or other appropriate units of geographic analysis. o Low-Income Populations: Low-Income Populations in an affected area are identified with the annual statistical poverty thresholds from the Census Bureau’s Current Population Reports on Income and Poverty.
Per the CEQ guidance, the U.S. Census data is typically used to determine minority and low- income population percentages in the affected area of a project in order to conduct a
Draft Environmental Assessment 86 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences quantitative assessment of potential environmental justice impacts. The Project Area that would be affected by the Proposed Action is located within Simpson County in Kentucky.
Table 3.20 Minority Population Data
Project Area Minority Individuals Minority Populations Low-Income Populations Simpson County Black/African:9.6% 13% 12.5% American Indian/Alaskan Native: 0.4% Asian: 0.8% Tw o or More Races: 2.1% Hispanic/Latino: 3.6% Commonw ealth Black/African:8.5% 12.5% 16.3% of Kentucky American Indian/Alaskan Native: 0.3% Asian: 1.6% Native Haw aiian/Pacific: 0.1% Tw o or More Races: 2.0% Hispanic/Latino: 3.9% U.S. Black/African:13.4% 23.7% 10.5% American Indian/Alaskan Native: 1.3% Asian: 5.9% Native Haw aiian/Pacific: 0.2% Tw o or More Races: 2.8% Hispanic/Latino: 18.5%
Minorities constitute 13% of the total population in Simpson County compared to 12.5% for the Commonwealth of Kentucky and 23.7% for the U.S. as of the 2019 U.S. Census of Population (Table 3.26). The estimated portion of the population of Simpson County that had income below the poverty level in 2019 was 12.5% which is lower than the state average of 16.3%, but higher than the U.S. average of 10.5%. Per Data USA information, the most common racial or ethnic group living below the poverty line in Simpson County, is reported to be White, followed by Black and Hispanic populations.
Environmental Consequences
No Action Alternative Under the No Action Alternative, there would be no changes to the Project Site attributable to the Proposed Action and, therefore, no disproportionately high and adverse direct or indirect impacts on minority or low-income populations.
Proposed Action Alternative Based on the analyses presented in Section 3.12.1, including the results of the USEPA EJSCREEN analyses, minority populations are present in the Project Area at higher rates than the state, but lower compared to nationwide. The Project Site has an estimated poverty rate that is higher than the nationwide rates, but lower compared to the state. The overall impacts of the Project, as described in other sections in this chapter, most of which would occur during the 12-18-month construction period, would be minor, and off-site impacts would be negligible. As such, no disproportionately high or adverse direct or indirect impacts on low-income populations due to human health or environmental effects are expected to result from the Proposed Action. Rather, the Project is expected to have beneficial effects to the local economy that would potentially benefit low-income populations. Horus Renewables
Draft Environmental Assessment 87 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences anticipates capital construction costs of $80 million for the Project Site. The Project Site is estimated to provide approximately 100 full-time jobs during construction for over a 12 to 18- month period. In addition, several local technicians and maintenances employees would be hired for the Project Site’s regular operation and maintenance for the life of the Project, which is expected to extend for 30 to 40 years once construction is complete. The Project would impact the local economy through the construction of the facility and also provide ongoing beneficial impacts from local and state taxes over the life of the Project. Based on the analysis presented in above section, residents of the census tracts containing the Project Area are considered both a minority population and low-income communities. However, based on the analysis of impacts for the resource areas presented in this EA, no significant adverse health impacts on member of the public or significant adverse environmental impacts on the physical environmental are anticipated.
3.13 Cumulative Impacts
Cumulative impacts occur when the effects of an action are added to or interact with other effects in a particular place and within a particular time. The combined incremental effects of human activity can pose a serious threat to the environment (EPA, 1999). The effects may be insignificant, but the impacts accumulate over time and can result in the degradation of environmental resources. The CEQ regulations for implementing the procedural provisions of the NEPA of 1969, as amended (42 USC 321 et seq.) define cumulative impact as: “…the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (federal or nonfederal) or person undertakes such as other actions” (40 CFR 1508.7). The CEQ developed the “Considering Cumulative Effects under the National Environmental Policy Act”, handbook to provide a method in addressing cumulative effects.
Desktop research of potential past, present, and future actions in the Simpson County was conducted. Resources examined included local and regional news sources, Simpson County government website records such as planning commission meetings, minutes, and public notices. The following state or locally funded project has been publicly announced in the vicinity of the Project Area with the potential to contribute to cumulative impacts associated with the Proposed Action:
In March of 2021, Matalco Kentucky, a newly formed venture of Matalco Inc., a Canada- based producer of aluminum products for the extrusion and forging manufacturing industries, announced its plans to locate its new factory in Simpson County, Kentucky. The new facility will be located in the 461,000-square-foot facility on 107 acres on 300 Brown Road in Franklin (located approximately 5 miles northwest of the Project Site). The estimated $53.5 million investment is expected to create 60 full-time jobs in the coming years.
To encourage the capital investment and job growth in the Franklin community, the Kentucky Economic Development Finance Authority (KEDFA) in January preliminarily approved a 10- year incentive agreement with Matalco Kentucky under the Kentucky Business Investment program. The performance-based agreement can provide up to $1 million in tax incentives based on the company's investment of $53.5 million and annual targets of creation and maintenance of 60 Kentucky-resident, full-time jobs across 10 years, and paying an average hourly wage of $25 including benefits across those jobs.
The cumulative impact of the effects of the Proposed Action when added to ongoing and future actions in the general area surrounding the project would be insignificant.
Draft Environmental Assessment 88 Horus Kentucky 1 Solar Project Chapter 3 – Affected Environment and Environmental Consequences
3.14 Unavoidable Adverse Environmental Impacts
The Proposed Action could cause some unavoidable adverse environmental effects (see Table 2-1). Specifically, construction activities would temporarily increase noise, traffic, and health and safety risks and temporarily affect air quality, GHG emissions, and visual aesthetics of the Project Site vicinity. Construction activities would primarily be limited to daytime hours, which would minimize noise impacts. Temporary increases in traffic would be minimized or mitigated by instituting staggered work shifts during daylight hours. Temporary increases in health and safety risks would be minimized by implementation of the Project health and safety plan. Construction and operations would have minor, localized effects on soil erosion and sedimentation that would be minimized by soil stabilization and vegetation management measures. The Project would change land uses on the Project Site from primarily agricultural to solar uses, where these practices are not presently occurring; however, renewable energy uses, including solar power, are permitted uses in this portion of Simpson County through the issuance of a CUP.
Consultation with appropriate federal and state agencies are currently on-going. In addition, draft of this EA will be issued for public review and comment for a minimum 30-day period from June 15 through July 15, 2021.
3.15 Relationship of Short-Term Uses and Long-Term Productivity
In this context, long-term impacts to site productivity would be those that last beyond the life of the Project. The Proposed Action would adversely affect current short-term uses of the Project Site by converting it from agricultural land to a solar power generating facility. The effects on long-term productivity would be minimal as existing land uses could be readily restored on the Project Site following the decommissioning and removal of the solar facility.
3.16 Irreversible and Irretrievable Commitments of Resources An irreversible or irretrievable commitment of resources would occur when resources would be consumed, committed, or lost because of the Project. The commitment of a resource would be considered irretrievable when the Project would directly eliminate the resource, its productivity, or its utility for the life of the Project and possibly beyond. Construction and operation activities would result in an irretrievable and irreversible commitment of natural and physical resources. The implementation of the Proposed Action Alternative would involve irreversible commitment of fuel and resource labor required for the construction, maintenance, and operation of the Project. Because removal of the solar arrays and associated on-site infrastructure could be accomplished rather easily, and the Project would not irreversibly alter the site, the Project Site could be returned to its original condition or used for other productive purposes once it is decommissioned. Most of the solar facility components could also be recycled after the facility is decommissioned.
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Horus Kentucky 1 Solar Project Chapter 4 – EA Recipients
CHAPTER 4 – ENVIRONMENTAL ASSESSMENT RECIPIENTS 4.1 Federal Agencies
U.S. Fish and Wildlife Service
4.2 Federally Recognized Tribes
Chickasaw Nation Choctaw Nation of Oklahoma Delaware Nation of Oklahoma Eastern Band of Cherokee Indians Eastern Shawnee Tribe of Oklahoma Miami Tribe of Oklahoma Muscogee Creek Nation Osage Nation Peoria Tribe of Indians of Oklahoma Quapaw Tribe of Indians Santee Sioux Nation of Nebraska Seneca-Cayuga Nation
4.3 State Agencies
Kentucky Department of Fish and Wildlife Kentucky Heritage Council Kentucky Office of State Archaeology Tennessee Department of Environment and Conservation Tennessee Historical Commission Tennessee Wildlife Resources Agency
4.4 Individuals and Organizations
Alphabetically list individuals and organizations here.
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Horus Kentucky 1 Solar Project Chapter 6 – Literature Cited
CHAPTER 5 – LIST OF PREPARERS 5.1 NEPA Project Management
Name/Education Experience Project Role J. Taylor Cates 5 years in environmental TVA NEPA Compliance and M.S. Environmental Science; planning and policy and NEPA Project Management B.S. Biochemistry compliance. Woo Smith 9 years in environmental Terracon NEPA compliance, B.A. Political Science and planning and NEPA document preparation, and Environmental Studies compliance project management
5.2 Other Contributors
Name/Education Experience Project Role Adam Dattilo 16 years in ecological restoration and Vegetation M.S. Forestry plant ecology, B.S. Natural Resource 9 years in botany Conservation Elizabeth B. Hamrick 18 years conducting field biology, 13 Terrestrial Ecology, M.S. Wildlife and Fisheries years technical writing, 9 years NEPA and Threatened and Science, ESA compliance Endangered Species B.A. Biology A. Chevales Williams 14 years of experience in water quality Surface Water B.S., Environmental monitoring and compliance; 13 years of Engineering NEPA planning and environmental services Craig Phillips 12 years sampling and hydrologic Aquatics B.S. and M.S. Wildland and determination for streams and wet Fisheries Science weather conveyances, 11 years in environmental reviews Carrie Williamson, P.E., 6 years Floodplains, 3 years River Floodplains CFM Forecasting, 2 years NEPA Specialist, 7 M.S., Civil Engineering; years compliance monitoring. B.S., Civil Engineering Michaelyn Harle 19 years in cultural resource management Cultural and Historic Ph.D., Anthropology; M.A. Resources, Section Anthropology; 106 Compliance B.A. Anthropology
Draft Environmental Assessment 93 Horus Kentucky 1 Solar Project Chapter 6 – Literature Cited
CHAPTER 6 – LITERATURE CITED
Area Development – Matalco Kentucky Plans Simpson County Kentucky, Alloyed Ingot Plant https://www.areadevelopment.com/newsitems/3-22-2021/matalco-simpson-county- kentucky.shtml
Census of Agriculture – Simpson County, Kentucky 2017 County Profile
City of Franklin and Simpson County, Kentucky. Zoning Regulations. Amended October 20, 2020.
Data U.S.A – Simpson County: https://datausa.io/profile/geo/simpson-county- ky#:~:text=From%202017%20to%202018%2C%20employment,Social%20Assistance%20( 893%20people).
Kentucky General Assembly: Kentucky Administrative Regulations Title 401 (401 KAR). 2021. Chapters 51: Attainment and Maintenance of the National Ambient Air Quality Standards, and 53: Ambient Air Quality: https://apps.legislature.ky.gov/law/kar/TITLE401.HTM
Kentucky Energy and Environment Cabinet (KEEC): KEEC. 401 KAR 51:005. 2021. Purpose and General Provisions: https://apps.legislature.ky.gov/law/kar/401/051/005.pdf
KEEC. 401 KAR 53:010. 2019. Ambient Air Quality Standards: https://apps.legislature.ky.gov/law/kar/401/053/010.pdf
Ke ntucky Transportation Cabinet (KYTC) KYTC. Interactive Statewide Traffic Counts Map: https://maps.kytc.ky.gov/trafficcounts/ KYTC. Traffic Database: https://datamart.kytc.ky.gov/EDSB_SOLUTIONS/CTS/
Kirkland Appraisals, LLC. March 10, 2021. Horus Kentucky 1 LLC Solar Project – Property Value Impact Study.
National Center for Biotechnology Information - Depczynski, J., Franklin, R. C., Challinor, K., Williams, W., & Fragar, L. J.. Farm Noise Emissions During Common Agricultural Activities (Tech.) (2005).
Tennessee Valley Authority (TVA). 1981. Class Review of Repetitive Actions in the 100- Year Floodplain, Federal Register Vol. 46, No. 76, April 21, 1981. 22845-22846.
TVA. 2019. Integrated Resource Plan (IRP), Volume I – Final Resource Plan
TVA. 2017. A Guide for Environmental Protection and Best Management Practices for TVA Construction and Maintenances Activities.
TVA. June 30, 2020. Categorical Exclusion Checklist for Proposed TVA Actions.
TVA. November 9, 2020. Categorical Exclusion Checklist for Proposed TVA Actions.
Draft Environmental Assessment 94 Horus Kentucky 1 Solar Project Chapter 6 – Literature Cited
TVA. December 16, 2020. Categorical Exclusion Checklist for Proposed TVA Actions.
TVA. Environmental Quality Protection Specifications for Transmission Line Construction.
TVA. Environmental Quality Protection Specifications for Transmission Substations or Communications Construction.
TVA. ROW Clearing Specifications.
TVA. Site Clearing and Grading Specifications.
TVA. Substation Lighting Guidelines.
TVA. Construction Guidelines Near Streams.
Terracon Consultants, Inc. (Terracon)
Terracon. April 2021. Architectural Survey for the Proposed Horus Kentucky 1 Solar Site in Simson County, Kentucky.
Terracon. August 2020. Karst Site Assessment of Proposed Hoffman Project in Franklin, Simpson County, Kentucky.
Terracon. December 2020. Karst Site Assessment of Proposed Hoffman-Summers Project in Franklin, Simpson County, Kentucky.
Terracon. April 2021. Phase I Archaeology Survey of Approximately 14 Miles of TVA Transmission Lines L5402 and L5775 for the Horus Kentucky 1 Solar Project in Sumner and Wilson Counties, Tennessee.
Terracon. May 2021. Phase I Archaeology Survey of Approximately 530 Acres at the Horus Kentucky 1 Solar Site and Approximately 6.85 Miles of TVA Transmission Line L5402 in Simpson County, Kentucky.
Terracon. February 2021. Phase I Environmental Site Assessment of Horus Kentucky 1 Project in Tyree Chapel Road, Franklin, Simpson County, Kentucky.
Terracon. May 2021. Threatened & Endangered Species Review of Hoffman TVA Solar in Tyree Chapel Road, Franklin, Simpson County, Kentucky.
Terracon. May 2021. Threatened & Endangered Species Review of Hoffman TVA Transmission Line in Simpson County, Kentucky and Sumner and Wilson Counties, Tennessee.
Terracon. April 2021. Wetland Delineation Report – Hoffman TVA Proposed Solar and Utility Transmission Line in Simpson County, Kentucky and Sumner and Wilson Counties, Tennessee.
U.S. Census
U.S. Census – QuickFacts – Kentucky: https://www.census.gov/quickfacts/KY
Draft Environmental Assessment 95 Horus Kentucky 1 Solar Project Chapter 6 – Literature Cited
U.S. Census – QuickFacts – Simpson County, Kentucky: https://www.census.gov/quickfacts/fact/table/simpsoncountykentucky,US/PST045219
U.S. Department of Agriculture
U.S. Department of Agriculture - Natural Resources Conservation Services – Web Soil Survey: https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx
U.S. Department of Agriculture - Natural Resources Conservation Services – Farms and Land in Farms 2019 Summary – February 2020
U.S. Dept. of Transportation, Federal Highway Administration - Highway Construction Noise Handbook. Jan. 2006.
U.S. Environmental Protection Agency
EPA. EJSCREEN: Environmental Justice Screening and Mapping Tool: https://ejscreen.epa.gov/mapper/
EPA. Clean Air Act General Conformity Requirements and The National Environmental Policy Act Process, April 2000: https://www.energy.gov/sites/prod/files/nepapub/nepa_documents/RedDont/G-DOE- cleanairactguidance.pdf
EPA. 2017. National Emissions Inventory (NEI) Dashboard – 2017 Sector Emissions Table: https://edap.epa.gov/public/extensions/nei_report_2017/dashboard.html#table-db
EPA. 2019. Air Quality Statistics Report 2019 Simpson County, Kentucky: https://www.epa.gov/outdoor-air-quality-data/air-quality-statistics-report
EPA. 2020a. Air Quality Statistics by County, 2019 (XLSX): https://www.epa.gov/air- trends/air-quality-cities-and-counties
EPA. 2020b. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2018: https://www.epa.gov/ghgemissions/inventory-us-greenhouse-gas-emissions-and-sinks- 1990-2018
EPA. 2021a. NAAQS Table: https://www.epa.gov/criteria-air-pollutants/naaqs-table
EPA. 2021b. Kentucky Nonattainment/Maintenance Status for Each County by Year for All Criteria Pollutants: https://www3.epa.gov/airquality/greenbook/anayo_ky.html
EPA. Sole Source Aquifers: https://epa.maps.arcgis.com/apps/webappviewer/index.html?id=9ebb047ba3ec41ada18771 55fe31356b
U.S. Fish and Wildlife Service: Information for Planning and Conservation (IPaC): https://ecos.fws.gov/ipac/
Draft Environmental Assessment 96 Horus Kentucky 1 Solar Project Chapter 6 – Literature Cited
U.S. Water Resources Council: 1978. Guidelines for Implementing Executive Order 11988, Floodplain Management. Federal Register Vol. 43, No. 29, February 10, 1978. pp. 6030-6054.
Weather Atlas: 2021. Kentucky, USA - Climate data and average monthly weather: https://www.weather-us.com/en/kentucky-usa-climate
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Draft Environmental Assessment 99
Appendix A – Consultation Correspondence & Comments on the Draft EA
Appendix A – Consultation Correspondence
Draft Environmental Assessment 101 Appendix B – Geotechnical/Karst Reports
Appendix B – Geotechnical/Karst Reports
Draft Environmental Assessment 102 Appendix C – Natural Resources Reports
Appendix C – Natural Resources Reports
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Appendix E – Phase I Environmental Site Assessment Report
Appendix D – Cultural Resources Reports
Draft Environmental Assessment 104
Appendix E – Phase I Environmental Site Assessment Report
Appendix E – Phase I Environmental Site Assessment Report
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Appendix E – Phase I Environmental Site Assessment Report
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